A ten year plan for the management of flooding from local sources Bath & North East Somerset’s Local Flood Risk Management Strategy 2015 – 2025 Issue 1.1 2 Bath & North East Somerset Local Flood Risk Management Strategy

Prepared by Burderop Park Swindon SN4 0QD Authors Jemma Bennett (CH2M) Document Status Alistair Cotton (CH2M) Jim Collings (Bath & North East Somerset Council) Title: Bath & North East Somerset Council’s Local Flood Risk Jim McEwen (Bath & North East Somerset Council) Management Strategy Daniel Parr (Bath & North East Somerset Council) Date: November 2015 Simon Morrisey (Bath & North East Somerset Council) Owner: Bath & North East Somerset Council Lead Local Flood Authority Stella Davies (formerly Bath & North East Somerset Council) (Drainage and Flooding Team) Version: 4.0 Approvals Revision History Produced by: Jemma Bennett (CH2M) Revision No. Description Date Signed Checked by: Alistair Cotton (CH2M) 1.0 Early Draft for comments 5th March 2015 Alistair Cotton from Bath & North East (CH2M) Approved by: Alistair Cotton (CH2M) Somerset Council 2.0 Draft for further comments 20th May 2015 Alistair Cotton from Bath & North East (CH2M) Somerset Council 3.0 Final Draft for Bath & North 10th Aug 2015 Alistair Cotton East Somerset Council (CH2M) 4.0 Final Document following 12th Nov 2015 Alistair Cotton Public Consultation (CH2M)

Bath & North East Somerset Local Flood Risk Management Strategy 3

Local Flooding

The summary below outlines what is classified as local flooding. Local flooding includes:

Surface water flooding Surface water flooding (also referred to as pluvial flooding or flash flooding), is rainwater, snow and other precipitation which runs across the surface of the ground and pools in low lying areas. To be classed as surface water flooding it must not have entered a watercourse, drainage system or public sewer. This type of flooding often occurs quickly during, or shortly after, a high intensity storm.

Groundwater flooding Groundwater flooding occurs where the water levels in rock and soil become high enough for the water to appear near to or above the ground surface. This may happen, for example, where there are underlying gravels, or porous or fractured rocks, allowing water to pass through. Flooding from natural springs would be classed as a form of groundwater flooding. Slow response means that groundwater flooding can occur a long time after prolonged or heavy rainfall and can last for a long time (often several weeks or months). Ordinary Watercourse flooding Ordinary watercourse flooding, also referred to as fluvial flooding, occurs when water overtops the banks of a stream or smaller watercourse. This can occur because there is more water draining into the channel than it can hold, or because it is blocked. Flooding from Main Rivers, (as defined by the Environment Agency) is not classed as ‘local’ flooding. 4 Bath & North East Somerset Local Flood Risk Management Strategy

Foreword

Flooding results in Flood risk from these sources is known as ‘local We must all recognise that flooding cannot be significant impacts to local flood risk’ in the legislation. completely prevented, but its impacts can be communities, businesses, reduced and managed through investment This Local Flood Risk Management Strategy has the economy and our and good planning. This Local Flood Risk been developed in collaboration with the Strategic environment. It causes Management Strategy represents the first step Flood Board, which includes representatives damage to property and in ensuring we have a sound and deliverable from Bath & North East Somerset Council, the infrastructure, and results strategy to manage local flood risk over the next Environment Agency, Wessex Water, Bristol Water in significant stress and ten years. and the Canal & River Trust. disruption to people. Yours Sincerely, Bath & North East Somerset Council in its role Flooding in Bath & North East Somerset occurs as Lead Local Flood Authority has also set up from rivers, surface water runoff, groundwater an Operational Flood Working Group, which and drainage networks (e.g. sewers and highway Councilor Liz Richardson discusses specific flooding or drainage issues drainage). No one organisation has responsibility (Chair of the Bath & North East Somerset with a view to developing practical measures to manage flood risk from all of these sources. Strategic Flood Board). to improve drainage or reduce flood risk. The Therefore, it is vital the Council, as a Lead importance of working with local communities is Local Flood Authority, works with others to fulfil also recognised, and this will primarily be achieved its responsibilities and manage flood risk for through Local Flood Representatives who act as communities, businesses and the environment. a point of contact between local communities and The Flood and Water Management Act (2010) Bath & North East Somerset Council’s Drainage gave Bath & North East Somerset Council, along & Flooding team (who undertake most of the with other local authorities across England and roles and responsibilities of the Lead Local Flood Wales, responsibilty to manage flood risk from: Authority). • surface water runoff; • groundwater, and; • Ordinary Watercourses. Bath & North East Somerset Local Flood Risk Management Strategy 5

Glossary

Please refer to Appendix F on page 127. 6 Bath & North East Somerset Local Flood Risk Management Strategy

Contents

Local Flooding 3 Section 3 – Roles and Responsibilities 23 Foreword 4 3.1 Partnership Working 24 Glossary 5 3.2 Who are the Risk Management Authorities 26 Section 1 – Introduction 9 3.3 Roles of Risk Management Authorities 27 1.1 Context of the Local Flood Risk Management Strategy 10 3.3.1 Bath & North East Somerset Council 27 1.2 The role of the Local Flood Risk Management Strategy 10 3.3.2 The Environment Agency 28 1.3 Who is the Strategy aimed at? 11 3.3.3 Wessex Water 28 1.4 What types of flooding are covered by the Strategy 11 3.3.4 Bristol Water 29 1.4.1 Main Rivers 12 3.3.5 Highways England (formally the Highways Agency) 29 1.5 The area covered by the Strategy 12 3.4 Existing activities 29 1.6 Links to other plans, policies and legislation 13 3.4.1 Highway drainage maintenance 29 1.7 How the Strategy has been prepared 15 3.4.3 Ordinary Watercourse maintenance 29 1.8 How the public will be involved 15 3.4.4 Maintenance of an asset register 29 3.4.5 Emergency planning and response 30 Section 2 - Strategy Objectives 17 3.4.6 Land Drainage Consent 31 Objective 1 – Improve understanding of local flood risk 20 3.4.7 Investigating flooding 31 Objective 2 – Promote community awareness and build capability for 3.5 Roles of Stakeholders and the Public 32 appropriate action 20 3.5.1 Reporting Flooding 32 Objective 3 – Manage local flood risk through capital and maintenance 3.5.1.1 Bath & North East Somerset Council 32 investment 20 3.5.1.2 Wessex Water 33 Objective 4 – Prevent inappropriate development that creates or increases 3.5.1.3 Bristol Water 33 flood risk 21 3.5.1.4 Environment Agency 33 Objective 5 – Improve flood preparedness, warning, ability to recover 21 3.5.2 Preparing for flooding 33 3.5.3 Role of property owners next to a watercourse 33 3.6 Responsibilities for surface water runoff from neighbouring property and land 34 Bath & North East Somerset Local Flood Risk Management Strategy 7

3.7 Responsibility for surface water runoff onto the public highway 34 Section 5 - Action Plan 49 3.8 Who else has a role 34 5.1 The Strategy Action Plan 50 5.2 Location-Specific Action Plan 64 Section 4 – Local Flood Risk in Bath & North East Somerset 35 5.3 Maximising the wider benefits of flood risk management 66 4.1 What is flood risk? 36 5.3.1 Environmentally responsible flood risk management 67 4.2 What is flood risk management? 39 4.3 Records of local flooding in Bath & North East Somerset 39 Section 6 - Funding Strategy 69 4.4 Potential flood risks in Bath & North East Somerset 39 6.1 The ‘Strategy’ funding approach 70 4.4.1 Flood risk from surface water 39 6.1.1 Funding capital works 70 4.4.2 Flood risk from groundwater 40 6.1.2 Funding maintenance of existing infrastructure 72 4.4.3 Flood risk from Main Rivers and Ordinary Watercourses 40 4.4.4 Flooding from sewerage systems 41 7.1 Governance, Monitoring and Review 75 4.4.5 Flooding from highway drainage 42 7.1 Governance for flood risk management 76 4.4.6 Flooding from other artificial sources 42 7.1.1 Resources 76 4.5 Future increases in flood risk 43 7.2 Monitoring 76 4.5.1 Climate change 43 7.3 Review and Update 78 4.5.2 New development 44 4.5.3 Asset deterioration and/or blockage 45 Appendix A Policies, legislations, plans, assessments and strategies 79 4.6 Communities most at risk from local flooding 46 Appendix B Statement of stakeholder engagement 89 Appendix C Roles and responsibilities of Risk Management Authorities 97 Appendix D Location-Specific Action Plan 105 Appendix E Review of funding sources 117 Appendix F Glossary 127 8 Bath & North East Somerset Local Flood Risk Management Strategy Section 1 Introduction 10 Bath & North East Somerset Local Flood Risk Management Strategy

1.1 Context of the Local Flood Risk Management Strategy This means the Council has a coordinating role for flood risk management across Bath and North East Somerset. The Council, as Lead Local Flood Bath & North East Somerset covers an area of approximately 350 km2, Authority, will work within the legislative framework to identify the appropriate and two thirds of the study area is designated as a green belt. The largest organisation to take a lead in any given location, working in partnership with urbanised areas within Bath & North East Somerset are Bath, Keynsham, other organisations as necessary. This will increase accountability to the Midsomer Norton and Radstock, and there are numerous historical villages public. and hamlets spread across 48 rural parishes which accommodate a substantial rural population. In our operational role the Council will take responsibility for working with communities and implementing measures on the ground to reduce flood risk Flooding is an important issue which affects individuals, businesses and from surface water, Ordinary Watercourses and groundwater. This will be communities, and can occur from rivers, surface water runoff, groundwater, done in partnership with organisations that have a responsibility for managing reservoirs, canals and drainage networks (e.g. sewers and highway drainage). flooding and local communities. We will undertake this on a prioritised basis, A Bath & North East Somerset regional Surface Water Management Plan with areas at greatest flood risk from surface water, Ordinary Watercourses was prepared in 2015 and identified that Bath, Keynsham, Whitchurch, Chew and groundwater remaining our highest priority. Magna, Chew Stoke, West Harptree, Midsomer Norton and Radstock are the locations in Bath & North East Somerset which have suffered the most Under the Flood and Water Management Act (2010) one of the statutory flooding. This has affected people, property, critical infrastructure and key requirements was for each Lead Local Flood Authority to develop, maintain, transport routes. apply and monitor a Local Flood Risk Management Strategy. The Local Flood Risk Management Strategy must: Until recently there has been limited understanding about who is responsible for different types of flooding and what can be done to reduce the risks. • communicate the roles and responsibilities of the various Risk Responsibilities have been clarified in recent policy and legislation changes. Management Authorities in Bath & North East Somerset (see Section 3 However, it is sometimes difficult to distinguish against different types and Appendix C); of flooding and it is therefore important that all organisations involved in • identify ‘locally significant’ flood risk, which are the priority risk areas (see managing flooding work in partnership to understand the causes of flooding the Bath & North East Somerset regional Surface Water Management Plan and what can be done to manage it. This document sets the strategy for and Section 4); ensuring this is achieved. • set objectives for managing ‘locally significant’ flood risk (see Section 2); 1.2 The role of the Local Flood Risk Management Strategy • outline measures to achieve the objectives set above (see Section 5); To improve the organisation of flood risk management in England, new • identify costs and benefits of the proposed measures, and how they will be legislation was passed in 2010 called the Flood and Water Management Act paid for (see Section 6 and Appendix E); (2010). Under the Flood and Water Management Act (2010) Bath & North East • communicate how the Local Flood Risk Management Strategy contributes Somerset Council is now a Lead Local Flood Authority1 1 The majority of the Lead Local Flood Authority roles and responsibilities are undertaken by the Drainage & Flooding team within the Council Bath & North East Somerset Local Flood Risk Management Strategy 11

to wider environmental objectives (refer to the accompanying Strategic • developers and their consultants; Environmental Assessment), and; • Risk Management Authorities (see section 3.2); • provide information on the review process for the Local Flood Risk • members of the Strategic Flood Board; Management Strategy (see Section 7.3). • members of the Operational Flood Working Group, and; The purpose of the Local Flood Risk Management Strategy is to help inform the Council, partners and communities about local flood risk, where it is most • the West of England Flood Risk Managers Group. significant, how it can be managed, and who is responsible for doing so. The Further details on members within these groups are included in the Glossary overall goal of the strategy is to help reduce risk to homes and businesses, in Appendix F. which will include buildings and areas with significant heritage value. The strategy sets out the objectives for doing this, and identifies the key 1.4 What types of flooding are covered by the Strategy actions we will take as the Lead Local Flood Authority, in partnership with other Risk Management Authorities, to manage local flood risk. Flooding In line with the Councils statutory responsibilities as a Lead Local Flood cannot be completely prevented, though its impacts can be reduced and Authority, the focus of the Local Flood Risk Management Strategy is on flood managed through investment, education and good planning. Therefore, risk from surface water, groundwater or Ordinary Watercourses, which we are through the Local Flood Risk Management Strategy there is also a need to now directly responsible for managing, and termed ‘local’ sources under the manage the expectations of partners and communities to achieve better legislation. local flood risk management that benefits communities in Bath & North East The Local Flood Risk Management Strategy does however also consider flood Somerset, and establish new policies that will help minimise the impact of risk in line with our coordinating responsibility. As part of this, it outlines the flooding. roles and responsibilities of other Risk Management Authorities who manage other types of flooding within Bath & North East Somerset, and how the Lead Local Flood Authority is working in partnership with these organisations. 1.3 Who is the Strategy aimed at? More details about roles and responsibilities of Risk Management Authorities The Local Flood Risk Management Strategy is aimed at a wide range of are included in Section 3 and Appendix C, and information on local flood risk partners and stakeholders, as each has an important role to play in managing in Bath & North East Somerset is included in Section 4. local flood risks in the Bath & North East Somerset area. These include: • communities, parish councils, flood action groups, and individuals; • businesses; • voluntary groups; 12 Bath & North East Somerset Local Flood Risk Management Strategy

1.4.1 Main Rivers Figure 1-1 Geographical extent of Bath & North East Somerset Council (courtesy of JBA Consulting)5 area It is important to outline that the Bath & North East Somerset area includes a number of Main Rivers* including the River Avon, Cam Brook, and the River Chew (as shown in Figure 1.1), which may present a flood risk to people living near to these. The operational management of flood risk from Main Rivers is undertaken by the Environment Agency who have developed plans and projects in partnership with other organistations. The Environment Agency has created a Bristol Avon Flood Management Plan that includes details about flood risk in the city of Bath and other locations within Bath & North East Somerset. Wherever the Environment Agency develops plans or projects to manage flood risk on Main Rivers, the Council will work with them as appropriate.

1.5 The area covered by the Strategy Bath & North East Somerset covers an area of approximately 350 km2, and two thirds of the study area is designated as a green belt. The largest urban areas within Bath & North East Somerset are Bath ( a World Heritage site), Keynsham, Midsomer Norton and Radstock, and there are numerous historic towns and villages spread across 48 rural parishes which accommodate a substantial rural population. This document presents the Local Flood Risk Management Strategy for the whole of the Council’s area which is depicted in Figure 1-1. 5 JBA Consulting (2015), Bath & North East Somerset Council Surface Water Management Plan

*A Main River is defined as a watercourse marked as such on the Environment Agency’s flooding maps on their website. Bath & North East Somerset Local Flood Risk Management Strategy 13

1.6 Links to other plans, policies and legislation There are a number of additional important flood related documents which have been produced for Bath & North East Somerset such as the Strategic Flood Risk Assessment and Surface Water Management Plan. Figure 1-2 outlines how the Local Flood Risk Management Strategy links with these other flood and coastal erosion risk management strategies and plans. As a UNESCO World Heritage site, the City of Bath has a World Heritage Site Management Plan (2010- 2016) which works in tandem with this strategy to outline the response to the threat of flooding and ensure the outstanding heritage in this important area is protected. There are also a number of pieces of legislation, planning documents and policies linked to the management of flood risk which also link to this Local Flood Risk Management Strategy, but again are not included specifically within it to avoid duplication. Details of these are included in Appendix A. 14 Bath & North East Somerset Local Flood Risk Management Strategy

Figure 1-2 How this Strategy fits in with other planning initiatives (extracted from National Flood and Coastal Erosion Risk Management Strategy)6

DCLG Defra Cabinet Office Overview Planning policy and Civil contingencies building regulations Flood and Coastal Erosion Risk Managment Policy

Environment Agency Strategic Overview – National FCERM Strategy Defra (guidance) surface water, groundwater, ordinary watercourses main rivers, reservoirs, sea, coastal erosion

Catchment Flood Flood Risk Shoreline Multi-agency Planning Local Development Management Plans Management Plans Management Plans flood plans Frameworks/ Neighbourhood Plans

Lead local flood authorities – local flood risk management strategies (building on surface water management plans, preliminary flood risk assessments etc)

Coastal erosion risk Lead local flood authorities: Districts/IDBs: Environment Agency: management authorities/ Local Resilience surface water and Delivery ordinary watercourses main rivers and the sea Environment Agency: Land use planning groundwater Forums application coastal erosion decisions

Water companies, reservoir owners, highway authorities

Third Party assets

Department for Communities Lead Local Flood Authorities and Local Government (county and unity authorities) Department for the Environment, District Council 6 The National Flood and Coastal Erosion Risk Management Strategy is available online. Food and Rural Affairs Major infrastructure owners Cabinet Office and third parties

Environment Agency Bath & North East Somerset Local Flood Risk Management Strategy 15

1.7 How the Strategy has been prepared 1.8 How the public will be involved The Local Flood Risk Management Strategy document has been developed The public have already had an important role in influencing this document by the Council as the Lead Local Flood Authority. To ensure a coordinated through the public consultation process as outlined above. This has allowed approach to flood risk management in the Bath & North East Somerset area, the public and other partners of the Council to have their say on the Local the Strategic Flood Board have been consulted to ensure the Local Flood Flood Risk Management Strategy document, its objectives and its action Risk Management Strategy aims and objectives align with those of other Risk plans. Management Authorities. The public now have an important ongoing role to play in helping reduce the A stakeholder workshop has also been undertaken to outline the purpose and risks from flooding within the region. In addition to being aware of the risks, function of the Local Flood Risk Management Strategy to a wider audience this includes: and gain initial feedback on the objectives and actions explained within this • reporting flooding incidents to the appropriate Risk Management Authority document. Amendments were made to the Strategy following this workshop. (see Section 3.4.1); Following this, a period of public consultation was held on the draft Local • taking action to reduce flooding to their property or land (see Section 3.4.2); Flood Risk Management Strategy to gain feedback on whether the strategy was considered to be effective and suitable for the whole of the Bath & North • cooperating with Risk Management Authorities where appropriate to help East Somerset area. The Local Flood Risk Management Strategy has been improve understanding about the mechanisms of flooding and help develop updated based on the comments received. effective approaches to manage risks, and; The full approach for stakeholder engagement is provided in Appendix B. • supporting the management of local risks through good land use practices, maintaining any privately owned flood risk structures or assets, and In addition to the Local Flood Risk Management Strategy itself, given maintaining watercourses where there are Riparian Owner responsibilities the number of designated sites and cultural heritage interest in the Bath (see Section 3.4.3). & North East Somerset district, it was felt that a Strategic Environment Assessment Report should be completed to accompany this Local Flood Risk Management Strategy and give consideration to the environmental implications of the objectives included within this strategy. 16 Bath & North East Somerset Local Flood Risk Management Strategy 2 Strategy Objectives 18 Bath & North East Somerset Local Flood Risk Management Strategy

It is helpful to describe local flood risk management in Bath & North East Figure 2-1 identifies how each of these objectives are linked to the three Somerset in three phases, which are illustrated in Figure 2‑1. The majority of phases of flood risk management. Objective 2 is an over-arching objective actions arising from the Local Flood Risk Management Strategy are related which needs to be promoted during all phases of local flood risk management. to managing the risks of local flooding, although there are some actions to It is vital that local communities are aware of local flood risks, know how support the planning for, warning of, and response to, flooding. The warning to prepare and respond to flooding, are empowered to take ownership of and responding to flooding incidents is primarily undertaken by the emergency local flood risk issues, and understand the roles and responsibilities of Risk planning authority7 with the support of the emergency services, including Management Authorities. Bristol & Avon Fire and Rescue and the Police. The measures proposed to help achieve these objectives are detailed in the A series of objectives have been defined to help structure and govern action plan provided in Section 5, and an explanation of the principles of each the implementation of the Local Flood Risk Management Strategy. These objective are contained below/overleaf. objectives are to: • Objective 1: improve understanding of local flood risk; • Objective 2: promote community awareness and build capability for appropriate action; • Objective 3: manage local flood risk through capital and maintenance investment; • Objective 4: prevent inappropriate development that creates or increases flood risk; • Objective 5: improve flood preparedness, warning and ability to recover.

7 This role is undertaken by the Emergency Planning and Business Continuity department within Bath & North East Somerset Council Bath & North East Somerset Local Flood Risk Management Strategy 19

Figure 2-1 Three phases of flood risk management in Bath & North East Somerset

Warn and respond to Manage the risks Emergency response undertaken flooding by the emergency planning • Improve understanding of local flood risk authority and emergency service • Promote community (Objective 1) awareness and build capability (Note: this is outside of the remit • Promote community awareness and build for appropriate action of the LFRMS capability for appropriate action (Objective 2) (Objective 2) • Manage local flood risk through capital and • Improve flood preparedness, maintenance investment (Objective 3) warning and ability to recover (Objective 5) • Prevent inappropriate development that creates or increases flood risk (Objective 4)

Plan for flooding • Promote community awareness and build capability for appropriate action (Objective 2) • Improve flood preparedness, warning and ability to recover (Objective 5) 20 Bath & North East Somerset Local Flood Risk Management Strategy

Objectives 1 2 3 Improve our understanding Promote community Manage local flood risk of local flood risk awareness and build capability through capital and for appropriate action maintenance investment To date a lot of work has been done by the Council Communities, individuals and businesses have an Although the Lead Local Flood Authority has and partners to improve understanding of flood risk important role to play in flood risk management, responsibility for taking a leading role in managing in the Bath & North East Somerset area. This has understanding what the risks are, and taking an local flood risk, it is not possible or appropriate for included recording where and when flooding occurs, active role in managing these risks. Further details the Lead Local Flood Authority to try to manage and assessments to ensure that new development on this essential role are discussed in Section all flood risk in isolation. To ensure that flood risk is considers flood risk.For further details refer to the 3.5. However, as part of the role as the Lead managed over the long term the Lead Local Flood Bath & North East Somerset Lead Local Flood Local Flood Authority there is also a need to help Authority will engage with all relevant partners to Authority website. ensure that useful information is provided to all develop long term, joined up approaches. This These studies and investigations have partially communities of Bath & North East Somerset. may involve other Risk Management Authorities or helped to meet this objective, but there are individuals, communities or developers i.e. anyone additional actions outlined within the Strategy who has a shared interest in mitigating specific Action Plan in Section 5 which the Lead Local flood risks. Through our role as the Lead Local Flood Authority has developed as part of the Local Flood Authority we will also prioritise our resources Flood Risk Management Strategy. These actions based on our improved understanding of where will help improve the understanding of all parties the risks are greatest. including the Council, communities, businesses, individuals, developers and Risk Management Authorities. They will also help ensure the appropriate party responsible to mitigate risks is identified, and that action is taken by the correct Risk Management Authority. Bath & North East Somerset Local Flood Risk Management Strategy 21 4 5 Prevent inappropriate Improve flood preparedness, development that creates warning and ability to recover or increases flood risk The Council holds roles as both the Local Local guidance in the form of the West of England The removal of all flood risk is not feasible and as Planning Authority and Lead Local Flood Authority, Sustainable Drainage Developer Guide has also such it is important to predict when flooding is and as such have responsibility to ensure that been published. This provides standards and likely to occur, warn people when there is a risk new development properly considers drainage guidance for developers, planners, designers to themselves or their properties, and thereafter and flood risk as part of the planning application and consultants on the requirements for design, help people to recover from the adverse effects of stage. In addition, the Lead Local Flood Authority approval and adoption of SuDS in the West of flooding. is a statutory consultee on all major planning England and Somerset. The guidance provides The Council is already responsible for planning applications9. The Lead Local Flood Authority information on the planning, design and delivery and responding to flood emergencies as also offers technical advice on local flood risk and of attractive, high quality and well integrated a Category 1 responder under the Civil drainage issues in Bath & North East Somerset, SuDS schemes, promotes the need for early Contingencies Act 2004, and works closely with and encourage pre-planning discussion to better consideration of Sustainable Drainage Systems, the Bristol & Avon Fire and Rescue Service10, the inform proposed drainage strategies and minimise and introduces the use of a “proof of concept” Police Service and the Environment Agency to do local flood risk. process to gain agreement in principle at an early this. stage from the Local Planning Authority. To support this the Bath & North East Somerset As part of the Local Flood Risk Management Placemaking Plan incorporates Sustainable As part of the Local Flood Risk Management Strategy the Lead Local Flood Authority has Drainage System policy, and links with the Core Strategy a number of actions have been identified developed a number of actions to ensure there is Strategy Key Policy CP5 Flood Risk Management to help strengthen the information available improved awareness about flood warnings and and CP7 Green Infrastructure, to ensure that all and ensure that inappropriate development is how to recover following a flood event. This is new sites are expected to incorporate sustainable prevented. This is described in Section 5. outlined further in Section 5.�� drainage systems to reduce surface water runoff and minimise its contribution to flooding.

10 The Fire and Rescue Service are not a Risk Management 9 Major development is defined in Article 2(1) of the Town and Authority and do not have any specific mandated Country Planning (Development Management Procedure) responsibilities around flood emergencies. However, (England) Order 2010. as part of the service they offer, they are often involved. 22 Bath & North East Somerset Local Flood Risk Management Strategy Section 3 Roles and Responsibilities 24 Bath & North East Somerset Local Flood Risk Management Strategy

3.1 Partnership Working Local Flood Representatives The Lead Local Flood Authority has established a number of working Local Flood Representatives are individuals nominated by their local groups which enable partnership working with other organisations and Risk community to act as a direct point of contact between the community and Management Authorities (see figure 3-1 and Section 3.2). Bath and North East Somerset Council. They provide first hand information on drainage and flooding issues that affect The Strategic Flood Board the community and relate these to the Council’s Drainage and Flooding Team The Strategic Flood Board facilitates partnership working for flood who can then escalate information to the Operational Flood Working Group. risk management in the Bath & North East Somerset area. It includes If you are interested in becoming a Local Flood Representative for your area representatives from Bath & North East Somerset Council, the Environment please contact your Parish Council or the Council’s Drainage and Flooding Agency, Wessex Water, Canal & River Trust, Bristol Water, Avon Fire and Team (email: [email protected] ). Rescue, and Avon and Somerset Police. Regional groups The Operational Flood Working Group The Lead Local Flood Authority also attend meetings with the South West The purpose of the Operational Flood Working Group is to discuss and agree Flood Risk Managers and West of England Flood Risk Working Groups, which ways to manage local flood risk. The Operational Flood Working Group will aids communication with other Lead Local Flood Authorities in the South discuss specific flooding or drainage issues with a view to coming up with West of England. practical measures to improve drainage or reduce flood risk. The group The established lines of communication between the various groups is shown consists of technical officers from the Council’s Drainage and Flooding team, in Figure 3-1. the Environment Agency and Wessex Water, as well as other invited Council officers and Local Flood Representatives as required. Bath & North East Somerset Local Flood Risk Management Strategy 25

Figure 3-1 Showing how Bath & North East Somerset Council as the Lead Local Flood Authority communicate with other partners who have roles and responsibilities for flood risk management. Risk Management Authorities have been defined in this diagram with (RMA) assigned next to their organisations title.

Lead Local Flood Authority Drainage & Flooding Team – Bath & North East Somerset Council sits on these groups established and lead these groups

West of England Flood Risk South West Flood Risk Strategic Flood Board & Local Flood Representatives Working Group Managers Group Operational Working Group • Representatives from local Including: Including: • Environment Agency (RMA) communities • Bristol City Council • Devon County Council • Wessex Water (RMA) • Parishes, Wards and Residents’ • North Somerset Council • Cornwall Council Groups • Avon Fire & Rescue • Somerset County Council • Somerset County Council • Avon and Somerset Police • South Gloucestershire Council • Bristol City Council • Bristol Water (RMA) • North Somerset Council • Local Highways Authority (RMA) • South Gloucestershire Council • Local Planning Authority (RMA) • Emergency Planning Authority Everybody in the Bath & North East Somerset area has the potential to play a (RMA) role in a partnership working arrangement, and getting the right mix of people involved is key to the success or failure of a flood improvement project. • Canal & Rivers Trust The Lead Local Flood Authority will facilitate the development of further partnership working where required, and when resources allow. 26 Bath & North East Somerset Local Flood Risk Management Strategy

3.2 Who are the Risk Management Authorities? Table 3-1 Overview of responsibility for flood risk management within Bath & North East Somerset Certain organisations were defined in the Flood and Water Management Act (2010) as Risk Management Authorities and given specific responsibilities around flooding. This includes both new responsibilities from the Flood Responsible Risk Management Authority and Water Management Act (2010), and longstanding ones from previous Flood Environment Bath & North Bristol Wessex Highways legislation such as the Highways Act (1980), and the Land Drainage Act Source Agency East Somerset Water Water England (1991). Council Within the Bath & North East Somerset region Risk Management Authorities Main River 3 include: The Sea 3 • Bath & North East Somerset Council; Surface Water 3 Surface Water (on • the Environment Agency; or coming from 3 3 the highway) • Highways England; Sewer Flooding 3 • Bristol Water; and Ordinary 3 Watercourse • Wessex Water. Ground Water 3 Table 3-1 provides an overview of these Risk Management Authorities and Reservoirs 3 3 their responsibilities for managing flood risk within the region. A summary of the key roles and responsibilities are provided in subsequent sections. Full details of all roles and responsibilities are included in Appendix C. Bath & North East Somerset Local Flood Risk Management Strategy 27

3.3 Roles of Risk Management Authorities As the Lead Local Flood Authority the Council is responsible for: All of the Risk Management Authorities in Bath & North East Somerset have • development, maintenance, application and monitoring of the Bath & North the following general duties and powers: East Somerset Local Flood Risk Management Strategy; • duty to co-operate with other Risk Management Authorities in the exercise • recording flood incidents, investigating and publishing reports on flooding of their flood and coastal erosion risk management functions, including incidents as appropriate11; sharing flood risk management data; • managing an Asset Register of structures or features which have a • duty to have regard for national and local flood and coastal erosion risk significant (as defined in this Section 3.4.4) effect on flood risk in the region; management strategies, and; • Ordinary Watercourse consenting and enforcement; • power to take on flood and coastal erosion functions from another Risk • designation of assets (structures and features) that affect flooding, and; Management Authorities when agreed by both sides (except those in relation to the function of the Lead Local Flood Authority or the Environment • statutory consultee for major planning applications with surface water Agency). implications. The specific roles of each Risk Management Authority are explained in the As the Local Highways Authority the Council is responsible for: following sections. • maintaining adopted highways within the Bath & North East Somerset area, • ensuring highways are not dangerous for traffic. 3.3.1 Bath & North East Somerset Council As the Local Planning Authority the Council is responsible for: The main responsibilities of the Council associated with flood risk management are as the: • preparing a Local Plan for development; • Lead Local Flood Authority; • considering flood risk assessments submitted in support of applications; • Local Highways Authority; • determination of planning applications, giving consideration for flood risk within the region, and; • Local Planning Authority, and; • working closely with the Lead Local Flood Authority to ensure that planning • Emergency Planning Authority. applications take adequate account of drainage requirements. The Council has an important role to play as the strategic leader for local flood risk management. This includes developing a Local Flood Risk Management Strategy, ensuring all Risk Management Authorities are aware of their responsibilities, and co-operate with each other through the Strategic Flood Board and the Operational Flood Working Group. Some of our functions are 11 This section of the Flood and Water Management Act (2010) also includes: Identifying which described below. authorities have relevant flood risk management functions to deal with flooding incidents, and what they have done or intend to do to ensure future risks are reduced. 28 Bath & North East Somerset Local Flood Risk Management Strategy

As the Emergency Planning Authority the Council has responsibility for: • carrying out flood defence works on Main Rivers, but the overall responsibility for maintenance lies with the Riparian Owner13; • planning for and responding to flood emergencies as a Category 1 responder under the Civil Contingencies Act 2004, and; • bringing forward flood defence schemes through the Regional Flood and Coastal Committees; • working closely with the Bristol & Avon Fire and Rescue Service12 and the Police Service to do this. • working with Lead Local Flood Authorities and local communities to shape schemes which respond to local priorities; • establishing and maintaining a register of reservoirs, and making this 3.3.2 The Environment Agency information available to the public; The Environment Agency is required to publish a National Flood and Coastal • acting as Enforcement Authority for reservoirs under their jurisdiction; Erosion Risk Management Strategy which provides a national framework for all sources of flooding and coastal erosion. Similar to the Local Flood Risk • using their role as the Enforcement Authority for reservoirs under their Management Strategy, it defines roles and responsibilities, and sets out some jurisdiction to enforce the Reservoirs Act 1975 and ensures flood plans are guiding principles for flood risk management. The Bath & North East Somerset produced for specified reservoirs. It should be noted that responsibility for Local Flood Risk Management Strategy must be consistent with this national carrying out work to manage reservoir safety lies with the reservoir owner/ strategy. operator who should produce the flood plans. The Environment Agency is also responsible for: 3.3.3 Wessex Water • having a strategic overview of flood risk from all sources; Wessex Water, as a water and sewerage company, has the following • managing flood risk from Main Rivers through preparation of plans and responsibilities related to flood risk management: policies (e.g. Catchment Flood Management Plans and Flood Risk Management Plans), and delivery of flood risk management schemes; • responding to flooding incidents involving their assets; • managing coastal erosion, but as Bath & North East Somerset does not • producing reports of the flood incidents as deemed necessary under contain any stretches of coastline this is not relevant for the management of Section 19 of the Flood and Water Management Act (2010); flood risks in Bath & North Somerset; • undertaking capacity improvements to alleviate sewer flooding problems • providing flood warnings to the public, protecting and improving the where it is economically viable to do so, and in accordance with their environment, and promoting sustainable development; business plan and performance commitments; • flood defence consenting; • providing, maintaining and operating public sewers systems and works for the purpose of effectively draining an area including adoption of new systems, and; 12 The Fire and Rescue Service are not a Risk Management Authority and do not have any specific 13 Riparian Owners are those who own land or property next to a river, stream or ditch. mandated responsibilities around flood emergencies. However, as part of the service they offer, they are often involved. Bath & North East Somerset Local Flood Risk Management Strategy 29

• have a role to play in integrated catchment management.It should be noted 3.4.2 Local Highway Authority emergency response that although a burst water main can also cause a property or road to There is an Emergency Duty Officer available 24 hours a day, 365 days a year, flood, this is excluded from the definition of flooding in the Flood and Water who is responsible for activating key Council staff in an emergency event, Management Act (2010). advising them of appropriate measures to take.

3.3.4 Bristol Water 3.4.3 Ordinary Watercourse maintenance Bristol Water are a water supply company only, and as such they do not have Regular maintenance works undertaken on Ordinary Watercourses helps any responsibility for sewer flooding. Bristol Water are however responsible ensure the free flow of water in these watercourses. This is necessary to for: alleviate flooding and to assist land drainage. The Lead Local Flood Authority • management of water impounding reservoirs, and have interests in; has identified 35 reaches of Ordinary Watercourses where clearance is required to reduce the risk of property flooding. These reaches are maintained • managing flooding caused by burst water mains within their area15, and;. on an annual basis. Furthermore, the Lead Local Flood Authority undertake • integrated catchment management. reactive maintenance works on trash screens to reduce the risk of blockage using permissive powers under the Land Drainage Act (1991). 3.3.5 Highways England (formally the Highways Agency) Highways England are responsible for: 3.4.4 Maintenance of an asset register • managing the quantity and quality of road runoff that is collected within the As highlighted in Section 3.3.1, the Lead Local Flood Authority are required Highways England network. to establish and maintain a register of structures and features which are considered to have a significant impact on flood risk, under Section 21 of the Flood and Water Management Act (2010). This register holds a record of 3.4 Existing activities information about each of those structures or features, including information Specific activities the Council is already undertaking to manage local flood risk about ownership and condition. The flood risk asset register is a live database, are outlined below. and new structures and features are added as information becomes available. The purpose of the asset register is to: 3.4.1 Highway drainage maintenance • inform the public of key flooding assets in their area; As outlined in Section 3.3.1 the Local Highways Authority have responsibilities • inform the Bath & North East Somerset Local Flood Risk Management under the Highways Act (1980). This includes ensuring that highway drainage Strategy; systems are maintained and that blockages on the highway are cleared, where reasonably practicable. • influence the maintenance regime of the assets, and;

15 It should be noted that flooding from burst water mains is specifically excluded from the Flood and Water Management Act (2010). 30 Bath & North East Somerset Local Flood Risk Management Strategy

• assist investigations of significant flood events (‘significant’ being as defined • provide advice and management of public health; below). • provide support and advice to individuals, and; The register is published on the the Council website and can currently be • assist with business continuity. found under the following link online: Lead Local Flood Authority maps. To support the development of business continuity, the Council have developed an Emergency Planning Protocol which can be found online: 3.4.5 Emergency planning and response Emergency planning protocol v10.pdf. As highlighted in Section 3.3.1, as the Emergency Planning Authority the It should be noted that the Emergency Planning Authority will only act in an Council has a responsibility for planning for and responding to emergencies; emergency that threatens serious damage to human welfare, the environment including flood emergencies. Guidance about emergency planning in or security, and may not respond immediately as a result of a flood event not Bath & North East Somerset Council is available on the Council’s website: considered to meet the criteria laid out in section 1 of Civil Contingencies Act Emergency-planning. 2004. Further advice on who can help during a flood is available online: Get During and after an emergency the Emergency Planning Authority: help during a flood. Please also see Section 3.5.1 and 3.5.2 for further details • coordinate emergency support within their own functions; on how to report and prepare for flooding. • work with the other Category 1 and 2 responders as part of the multi- agency response; • coordinate emergency support from the voluntary sector; • liaise with central and regional government departments; • liaise with essential service providers; • open rest centres; • manage the local transport and traffic networks; • mobilise trained emergency social workers; • provide emergency assistance; • deal with environmental health issues, such as contamination and pollution; • coordinate the recovery process; • manage public health issues; Bath & North East Somerset Local Flood Risk Management Strategy 31

3.4.6 Land Drainage Consent The investigations will identify which Risk Management Authority is responsible for the flood incident. The relevant Risk Management Authority will then be Under Schedule 2 of the Flood and Water Management Act (2010) the Lead required to prepare a report detailing the cause of flooding, the consequences Local Flood Authority has a duty to consent works and a power to undertake of the flood event and the actions taken to deal with the event during and after enforcement on Ordinary Watercourses under changes to the Land Drainage the flooding, in accordance with the requirements of Section 19 of the Flood Act 1991 (sections 23, 24 and 25). The duty to consent enables the Lead and Water Management Act (2010). Investigations will involve consultation Local Flood Authority to approve or reject applications for works on Ordinary with the relevant Risk Management Authorities, landowners and private Watercourses depending on the impact of the proposed works on flood risk. organisations involved, all of whom we will work with to ensure cooperation. As part of this role the Lead Local Flood Authority review proposals from These reports will be important tools that will bring all useful information applicants who intend to carry out works (whether temporary or permanent) together, providing a better picture and understanding of situations, outlining that may construct or alter any mill, dam, weir, and any culvert which is likely to possible causes of flooding and identifying potential long-term solutions. affect the water flow on an Ordinary Watercourse. These reports will also include further recommendations for future flood The reason for this consenting process is to ensure that any works do not risk management actions that could be undertaken to address and resolve endanger life or property by increasing the risk of flooding or cause harm to the flooding. Reports will be available to anyone on request within three months of water environment. an incident being reported to the Lead Local Flood Authority. However, there 3.4.7 Investigating flooding are cases where this timeframe will be extended (e.g. if widespread flooding occurred across the area). The Lead Local Flood Authority have a duty to record and investigate significant flooding events (regardless of source) under Section 19 of the Flood and Water Management Act (2010). There is no national definition of significant and it is up to the Lead Local Flood Authority to decide what flooding incidents are locally important to them and are worth recording and investigating. Any of the following will trigger an investigation and be classified as significant: • five or more dwellings at an urban location experience internal flooding; • two or more dwellings at a rural location experience internal property flooding; • where the event resulted in a loss of life, or; • where critical infrastructure (e.g. power station, pump station, electricity supply, critical transport route) was affected by flooding for a significant period of time. 32 Bath & North East Somerset Local Flood Risk Management Strategy

3.5 Roles of Stakeholders and the Public As highlighted in Section 1.8, all residents have a role to play in helping to Council Connect service: manage flooding. Further details regarding these roles is outlined in Section Online forms: www.bathnes.gov.uk/reportit 3.5. Email: [email protected] Twitter: @ccbathnes 3.5.1 Reporting Flooding Telephone: 01225 39 40 41

In a flooding emergency contact the emergency services. Text (SMS): 07797 806 545 Following a flooding incident, it is important to report flooding to the The more information that can be provided the better, with photos being appropriate organisation to ensure appropriate action can be taken and to particularly useful. Council Connect, or a Local Flood Representative, will then help improve understanding on where and when flooding is occurring within pass the information to the Lead Local Flood Authority for them to consider the region. and escalate as appropriate. Issues may be discussed at an Operational The following sections provide guidance and contact details on who to Flood Working Group meeting or passed to the relevant Risk Management contact in the Bath & North East Somerset area. Authority. It should be noted that unless the flooding event is classed by the Emergency 3.5.1.1 Bath & North East Somerset Council Planning Authority as an emergency, it is unlikely that an immediate response Council Connect, and/or a Local Flood Representative, should be contacted: will be provided during a flood event. As highlighted in Section 1.8 it is the responsibility of residents to prepare themselves for flooding. Please refer to • where flooding has led to internal property flooding; Section 3.5.2 on further information on how to do this. • where there is a maintenance issue with a watercourse that may result in flooding of properties. For instance overgrown vegetation impeding flows, or other restrictions or blockages such as fallen trees or trash that could result in property flooding; • maintenance issues with watercourse structures that may result in flooding of properties (e.g. blocked culverts or trash screens); • where there is actual evidence of flooding from an Ordinary Watercourse; • where surface water runoff from land may be flooding roads or property, or; • where evidence of groundwater flooding is observed. Bath & North East Somerset Local Flood Risk Management Strategy 33

3.5.1.2 Wessex Water There may be opportunities for support with helping to prepare properties and premises against flooding, but this will be dependent on individual If flooding is considered to have occurred as a result of problems with sewers circumstances. Further details on potential financial support is outlined in anywhere in Bath & North East Somerset, or from mains water supply in the Section 6 and Appendix D. Bath area, then Wessex Water should be contacted on 0345 600 4 600. 3.5.3 Role of property owners next to a watercourse 3.5.1.3 Bristol Water If a property is adjacent to or backs onto a river, stream or other watercourse If flooding has resulted from a burst or leak from a mains water supply in Bath then it is likely that the land owner will be the Riparian Owner and as such be & North East Somerset (except for Bath area) then Bristol Water should be held to own the land up to the centre of the watercourse. contacted on 0800 801 011. Riparian Owners have a right to protect their property from flooding and erosion, but will need to discuss the method of doing this with the Lead 3.5.1.4 Environment Agency Local Flood Authority if the watercourse is an Ordinary Watercourse, or the Environment Agency if the watercourse is classified as a Main River The Environment Agency should be contacted on 0800 80 70 60 to report (as outlined in Section 4.4.3). Riparian Owners also have responsibility for flooding from Main Rivers or the sea. They also provide other useful advice on maintaining the bed and banks of the watercourse and ensuring there is no who to contact in an event of a flood online: Get help during a flood. obstruction, or diversion to the flow of the watercourse.

3.5.2 Preparing for flooding If you are a riparian owner there is useful Even where drainage and flood risk systems are functioning in accordance information in the Environment Agency’s with their design standards there will always be situations when rainfall exceeds the capacity of these systems and flooding will occur. Consequently document, available online: ‘Living on the Edge.’ it is important that householders and businesses, whose homes are at risk of flooding, take steps to ensure that their house is protected and ensure they do not increase the risk of flooding to others. The Environment Agency provides information on what to do to prepare a household for flooding and what to do during a flood: Prepare for a flood. This includes how to make a flood plan which will help you decide what practical actions to take before and after a flood. 34 Bath & North East Somerset Local Flood Risk Management Strategy

3.6 Responsibilities for surface water runoff from 3.8 Who else has a role? neighbouring property and land Utility and infrastructure providers such as Network Rail, energy companies All property and land owners are encouraged to adopt good land use and telecommunication companies are not Risk Management Authorities, practices and adequately maintain their drainage systems to avoid surface but have a crucial role to play in flood risk management. Their assets can be water runoff from causing problems for neighboring property and land. important consideration in planning for flooding, and although they already maintain plans for the future development and maintenance of the services However, under common law, land or property owners are responsible for the they provide, it is important that they factor in flood risk management issues drainage of their own land. Higher land owners have the right to make natural into this planning process. discharge to lower ground, but the lower landowner does not have a duty to accept that runoff. Utility and infrastructure providers may therefore wish to invest time and resources into developing and delivering aspects of the Local Flood Risk A dispute between neighbours over problems resulting from surface water Management Strategy in order to protect their assets and customers. runoff is a civil matter.

3.7 Responsibility for surface water runoff onto the public highway Drainage of the highways, and maintenance of highway drainage features are the responsibility of the Local Highways Authority. Under Section 163 of the Highways Act (1980) the Local Highways Authority have powers to issue notice to adjoining occupiers to construct, and thereafter maintain, “channels, gutters or downpipes as may be necessary to prevent: • water from the roof or any other part of the premises falling upon persons using the highway, or; • so far as is reasonably practicable, surface water from the premises flowing onto, or over, the footway of the highway.16

16 Highways Act (1980) online: Section 4 Local Flood Risk in Bath & North East Somerset 36 Bath & North East Somerset Local Flood Risk Management Strategy

This section provides an overview of the current, and potential future flood risk in Bath & North East Somerset. It draws primarily on information contained within the Bath & North East Somerset regional Surface Water Management Plan, but also the Preliminary Flood Risk Assessment produced in 201117. This section should therefore be read in conjunction with the Surface Water Management Plan available online: Lead Local Flood Authority website.

4.1 What is flood risk? Flood risk is a combination of the probability and consequence of flooding from any, or all, sources. High flood risk can endanger lives, damage buildings and infrastructure, historic structures, archaeology and settlements. Flood risk means risk from all sources of flooding. This includes from: • rivers; • the sea; • directly from rainfall on the ground surface (surface water runoff); • rising groundwater; • overwhelmed sewers and drainage systems; • from reservoirs; • canals; • lakes, or; • other artificial sources18.

17 Preliminary Flood Risk Assessment.pdf 18 Extracted from: Communities for Local Government (2012), Technical Guidance to the National Planning Policy Framework. Bath & North East Somerset Local Flood Risk Management Strategy 37

Flood risk management measures can be broken down into broad themes as detailed below and in figure 4-1

Measure Description Typical examples Investigations Aim to better understand the cause of flooding to improve the confidence • studies (e.g. Surface Water Management Plan); in decision-making. • site walkovers; • surveys, or; • drainage and overland modelling studies. Source Source control measures aim to control flood water at their source by • introducing sustainable drainage systems / green infrastructure control increasing storage, reducing the rate of runoff or increasing the volume / rainwater harvesting; of water which soaks into the ground. Sustainable drainage systems • improving land management practices, or; are often an effective means to implement source control. Sustainable • intercepting and diverting pluvial runoff. drainage systems encompass a variety of measures such as permeable paving which allows more water to soak into the ground than traditional impermeable road and path surfaces. Other sustainable drainage measures may include introducing ponds and wetlands that can hold flood water, or swales and detention basins which slow the movement of water and reduce the volume of runoff. Source control measures can also integrate with re-use of water through (grey-water recycling or rainwater harvesting). Pathway Pathway measures aim to effectively manage the movement of flood • storage above or below ground; water through both natural and manmade drainage systems. Measures • management of exceedance flows (e.g. re-profiling road); may be structural, for example involving the development of new drainage • increasing capacity of urban drainage network (sewer or systems, or separating foul and surface water sewers. They may be non- highway drainage); structural, for example encouraging land management practices which • increasing capacity of drains/watercourses; reduce runoff. Maintenance of existing drainage infrastructure is also an • raising/creating flood defences; important aspect to managing flood risk. It can reduce flood risk with minimal capital investment, freeing up funds for measures elsewhere. • removing culverted sections of watercourses and replace with open channels; • enhancing maintenance of gullies / drainage network; • enhancing maintenance of watercourses/culverts, or; Receptor Measures aim to reduce the likelihood and/ or impact of flooding on • introducing individual property level protection / resilience level people, property and environment. measures; • improving flood warning • planning policies to prevent inappropriate development; • raising awareness and education, and; • promoting community level resilience. 38 Bath & North East Somerset Local Flood Risk Management Strategy

Figure 4-1 Flood risk management (Source Control, Pathway, Receptor)

Receptor: Pathway: Receptor: Improved weather warning Managing flows Improveed resilience overload and resistance

Receptor: Planning policies to influence development

Receptor: Source: Social Limit flows entering change, education the system Receptor: awareness Temporary or demountable flood defences

Pathway: Source: Pathway: Pathway: Land management Sustainable Separation of Improved practices drainage system foul and surface maintenance water sewers Pathway: Pathway: Maximise capacity Maximise river/water in drainage system course capacity Bath & North East Somerset Local Flood Risk Management Strategy 39

4.2 What is flood risk management? 4.4 Potential flood risks in Bath & North East Somerset The ultimate aim of flood risk management is to reduce the likelihood and/ The information in Sections 4.4.1 to 4.4.6 describe the nature of flood risk in or impact of potential flood risks, but there are a number of stages which are Bath & North East Somerset from a range of sources. Information on local needed in order to do this effectively. For example without understanding the flooding is summarised in Table 4 2. cause of flooding properly, the solution to reduce flood risk would not be as effective. 4.4.1 Flood risk from surface water 4.3 Records of local flooding in Bath & North East Somerset Surface water flooding, also referred to as pluvial flooding or flash flooding, One of the purposes of the Bath & North East Somerset regional Surface Water is “rainwater, including snow and other precipitation, which is on the surface Management Plan was to collate information and map recent and relevant flood of the ground and has not entered a watercourse, drainage system or public incidents within Bath & North East Somerset, to help inform what the local sewer”.19 When this happens the water either ponds on the surface or runs flood risk issues are within the region. over it and this can potentially lead to flooding. Recorded flooding incidents in the Bath & North East Somerset regional In 2014 the Environment Agency produced the Updated Flood Map for Surface Surface Water Management Plan were based on the information supplied by Water to identify areas that were vulnerable to flooding from surface water. the partners and stakeholders involved in the management of surface water, Risk of flooding from surface water maps. The Bath & North East Somerset Main Rivers, Ordinary Watercourses, groundwater and sewer flooding. This regional Surface Water Management Plan was completed in July 2015 using included data from Bath & North East Somerset Council, the Environment the updated data from the Environment Agency to better understand the Agency, Wessex Water, and the Canal & River Trust. risk of flooding from surface water. For this Bath & North East Somerset regional Surface Water Management Plan a count of the number of residential Based on this, over 990 recorded flood incidents of recent and relevant properties, critical infrastructure and emergency service assets at risk of flooding were recorded in the region between 2009 and 2014. Records of flooding was undertaken, for all of the mapped return periods in the Updated flooding prior to 2009 were removed to prevent any misrepresentation of Flood Map for Surface Water, which is shown in Table 4‑1. recorded flood incidents which may now have been actioned. Further details on the methodology used to analyse flooding incidents is detailed in the Bath & North East Somerset regional Surface Water Management Plan report. These records were used to develop a Flood Incident Register and Interactive Maps of Local Flood Incidents. These outputs are available in the Bath & North East Somerset regional Surface Water Management Plan report. As demonstrated on the Interactive Maps of Local Flood Incidents, flooding occurs 19 Extract from: Department for Environment, Food and Rural Affairs and the Environment Agency across the region, although there are notable clusters of flooding in Bath, (2011), Understanding the risks, empowering communities, building resilience: the national flood Keysham, Whitchurch, Chew Magna, Chew Stoke, West Harptree, Midsomer and coastal erosion risk management strategy for England. Norton and Radstock. 40 Bath & North East Somerset Local Flood Risk Management Strategy

Table 4-1 Estimated number of receptors at risk from surface water Flooding of this type tends to occur after long periods of sustained heavy flooding (extracted from Bath & North East Somerset regional Surface Water rainfall and can last for weeks or even months. The areas at most risk are often Management Plan) low-lying areas where the water table is more likely to be at a shallow depth; flooding can be experienced through water rising up from the underlying aquifer Residential Critical Emergency Probability20 or from water flowing from springs or when watercourses force fluvial flood Properties Infrastructure Responders water into the ground. High 302 11 0 The Bath & North East Somerset regional Surface Water Management Plan has Medium 737 24 0 noted that no recent and relevant flood incidents have been directly attributed Low 3039 77 2 to groundwater. There is likely to be some interaction between Ordinary Watercourses, surface water runoff, and groundwater for a number of flood incidents (e.g. as has previously occurred in Chew Magna when fluvial flooding The Lead Local Flood Authority has also completed a number of other studies infiltrated into the ground and caused properties to suffer from groundwater looking into the effect of surface water flooding within the region. These include flooding). the following: • a Preliminary Flood Risk Assessment; 4.4.3 Flood risk from Main Rivers and Ordinary Watercourses • Surface Water Assessment for Weston (Bath), and; Flooding from rivers occurs when water overtops the banks of the channel. • Section 19 flood investigations for Chew Stoke, Chew Magna and This can occur because there is more water draining into the channel than it Broadmead Lane Industrial Estate (Keynsham). can hold, or because it is blocked. In England watercourses are defined as either Ordinary Watercourses or Main Rivers. Main Rivers are generally the Further information on these and other studies which have been completed larger arterial watercourses, but smaller watercourses can be designated if are provided on the Bath & North East Somerset website: Lead Local Flood they pose a significant flood risk. Flooding from Main Rivers is managed by the Authority website. Environment Agency using its permissive powers under the Environment Act (1995). The Lead Local Flood Authority has permissive powers to carry out 4.4.2 Flood risk from groundwater works on Ordinary Watercourses within the area to manage risks from flooding, Groundwater flooding occurs where the water levels in the ground becomes but Riparian Owners (see Section 3.4.3) have the primary responsibility for high enough for the water to appear above the ground surface. This may managing these risks. happen, for example, where there are underlying gravels, or porous or fractured The Environment Agency has published ‘Risk of Flooding from Rivers and Sea’ rocks, allowing water to pass through. Flooding from natural springs would be maps of flood risk from Main Rivers and Ordinary Watercourses, which are classed as a form of groundwater flooding. available online.

20 High means that each year, this area has a chance of flooding of greater than 1 in 30 (3.3%). Medium means that each year, this area has a chance of flooding of between 1 in 100 (1%) and 1 in 30 (3.3%). Low means that each year, this area has a chance of flooding of between 1 in 1000 (0.1%) and 1 in 100 (1%). Bath & North East Somerset Local Flood Risk Management Strategy 41

4.4.4 Flooding from sewerage systems Figure 4-2 Responsibility of householders and sewerage companies (from Ofwat website) Flooding from sewerage systems occurs when the capacity of the drainage network is exceeded. This can be due to blockage, failure of equipment or overloading of sewers due to rainfall. Sewerage companies are responsible for Residential Property Residential Property managing sewerage networks under the Water Industry Act (1991). Wessex Water maintain records of flooding from foul sewers, combined sewer and surface water sewers. The difference between these types of sewer are explained in the glossary in Appendix F. In 2011 water companies in England and Wales took on new responsibilities for private drainage, under the transfer of private sewers21. Under this transfer most private sewers, lateral drains and pumping stations that form part of the sewer or lateral drain that connect to the public sewer network were transferred to the ownership of the water companies. Homeowners remain responsible for Footpath household drainage to the point at which it connects to the public sewer. This is normally at the property boundary, as illustrated in Figure 4-2. Public highway

Public sewer, responsibility of sewerage company Lateral, responsibility of sewerage company

Drain, responsibility of homeowner

For the Bath & North East Somerset regional Surface Water Management Plan, Wessex Water provided a list of sewer flooding incidents for the period 2013-2014, including those attributable to surface water flooding. Wessex Water has identified postcode locations for 44 occurrences of sewer flooding during this period. These have been mapped and referred to as the Interactive Maps of Local Flood Incidents. This is available in Appendix B of the Bath & North East Somerset regional Surface Water Management Plan. Where there is overlap with other sources of flooding (e.g. surface water runoff or Ordinary Watercourses) there may be opportunities for Risk Management Authorities 21 Consumer issues, available online: Web sewer transfer. Note not all transfers of ownership have to co-fund or co-deliver flood risk management schemes to address flooding yet been completed. more cost effectively. 42 Bath & North East Somerset Local Flood Risk Management Strategy

4.4.5 Flooding from highway drainage The Environment Agency act as the enforcement authority for reservoirs . Responsibility for carrying out work to manage reservoir safety lies with the Appropriate highway drainage is required in order to ensure the highway is reservoir owner/operator such as Bristol Water. safe. What action is reasonable will depend on a number of factors, but to ensure compliance with Section 41 of the Highways Act 1980, the Council The Environment Agency has published mapping to indicate the area that operates a comprehensive inspection and repair regime in accordance with could be flooded if a large reservoir were to fail and release the water it holds. the National Code of Practice. Environment Agency flood risk maps. It should be noted that the majority of roadside ditches are the responsibility of adjacent landowners, unless the ditch was constructed by the Highways Authority solely for the purpose of draining the highway. Highways England is responsible for maintaining drainage systems which drain highways on trunk roads in their network. A significant proportion of the recent and relevant recorded incidents of flooding are from highway drainage systems. However, it should be noted that this might not actually reflect the true split of flooding, and may just be the incidents of flooding that the Council were previously responsible for, and hence have been reported to the Council and recorded on its systems.

4.4.6 Flooding from other artificial sources Flooding from other artificial sources includes risk from reservoirs, canals and manmade structures. The flood risk along canals is generally considered to be low as they are not subject to the same flows as other water bearing infrastructure. The Canal & River Trust do however keep records of flooding along canals within the Bath & North East Somerset area and to date there have been limited flooding incidents recorded. Reservoirs are designed to accommodate large quantities of water and although it is unlikely that flooding will occur in Bath & North East Somerset, there would be significant consequences if a reservoir structure was to fail. Bath & North East Somerset Local Flood Risk Management Strategy 43

4.5 Future increases in flood risk Table 4-2 Sensitivity ranges for considering climate change impacts on flooding (extracted from National Planning Policy Framework Technical There are a number of factors which will influence flooding in the future. Guidance) This will result in an increase in the risk of flooding across Bath & North East Somerset unless this is adequately planned for and managed. Development Design Life Although there are many factors that can increase flood risk, the major risks 1990 2025 2055 2085 Parameter include: to 2025 to 2055 to 2085 to 2115 Peak river • climate change; +10% +20% +20% +20% flow • new development, and; Peak rainfall +5% +10% +20% +30% • deterioration or blockage of drainage infrastructure and flood defence intensity structures. As part of the Bath & North East Somerset regional Surface Water Management Plan additional surface water modelling was undertaken to 4.5.1 Climate change assess the impact of climate change on surface water flood risk in Bath Climate change is predicted to result in more severe extreme weather which & North East Somerset. A 30% uplift was applied to the rainfall (as per could lead to extreme floods with more serious consequences. Although this Table 4‑2), and the Bath & North East Somerset regional Surface Water will vary depending on the catchment, the UK Climate Projections 2009 Study Management Plan report notes that: (described in the Glossary in Appendix F) predicted that by 2050 the South “The results show that climate change is likely to have a notable impact on West of England will experience winter rainfall increases of around 12% (very flood risk across the Bath & North East Somerset area. Flood outlines for an likely to be between 2 and 26%); rainfall on the wettest day in winter will be event with a 1 in 100 chance of occurring in any given year (i.e. a storm event increased by around 9% (very unlikely to be more than 22%); and peak river with a 1% annual exceedance probability) are slightly larger than present volumes in a typical catchment are likely to increase by between 9 and 18%. day outlines in all flooding wet-spot locations. Increases in flood extents are generally more pronounced in flatter valleys where water would spread further at lower depths. In steep-sided valleys flood extents do not increase significantly, however flooding becomes deeper.”22

22 JBA Consulting (2015), Bath & North East Somerset Surface Water Management Plan 44 Bath & North East Somerset Local Flood Risk Management Strategy

Further analysis undertaken for the Bath & North East Somerset regional Table 4-3 Surface water drainage policies and legislation for development Surface Water Management Plan indicated that with 30% allowance for climate change, an additional 656 residential properties, 22 critical Policy/ legislation infrastructure locations and two emergency responders may be at risk of National Planning Policy Framework Paragraph 103 surface water flooding following an event with a 1 in 100 chance of occurring Sustainable drainage systems: Written statement (HCWS161) 18 in any given year (i.e. a storm event with a 1% annual exceedance probability). December 2014 Bath & North East Somerset Council emerging Placemaking Plan: 4.5.2 New development Policy SU1 If new development and changes in land use are not properly controlled and Building Regulations Part H (HM Government, 2010) managed this could cause increased runoff during rainfall events and result in Bath & North East Somerset Council’s Core Strategy increased flood risk. The Lead Local Flood Authority are a Statutory Consultee for major planning applications and will scrutinise applications in terms of surface water flood risk and sustainable drainage. This will also provide guidance on all applications which have surface water implications and may affect local flood risk. When making planning decisions the Local Planning Authority and Lead Local Flood Authority work together to review development proposals to ensure that inappropriate new developments are prevented or directed away from high risk flood areas, and that appropriate drainage is to be provided. This includes a review of whether suitable consideration has been given to climate change. There are a number of national and local documents which need to be considered by developers prior to applying for a Planning Application. Table 4-3 sets out the policies and legislation in relation to the management of surface water drainage for new developments. Table 4-4 sets out the national and local guidance in relation to the management of surface water drainage for new developments. Bath & North East Somerset Local Flood Risk Management Strategy 45

Table 4-5 Surface water drainage guidance for development increase in future flood risk may be seen unless there is investment to ensure drainage infrastructure is functioning. The Risk Management Authorities listed Guidance in Section 3 maintain their assets to minimise the risks they are responsible Planning Practice Guidance (Department for Communities and Local for. The Lead Local Flood Authority also maintain an asset register, detailed in Government) Section 3.3.2, and this is a vital tool to help manage flood risk. Non-statutory technical standards for sustainable drainage systems As part of the Bath & North East Somerset regional Surface Water (Department for Environment, Food & Rural Affairs, 2015) Management Plan a high level analysis was undertaken to look at critical West of England Sustainable Drainage Developer Guide infrastructure assets comprising of bridges, culverts and screens. These (West of England Partnership, 2015) structures could contribute to significant flooding if they became blocked or Surface Water Management Plan for Bath & North East Somerset were in a state of collapse requiring repair. (Bath & North East Somerset Council, 2015) This high level analysis identified 27 structures which are deemed critical for Environment Agency Local Flood Risk Standing Advice maintenance to avoid blockage. The Strategy Action Plan (section 5.1) sets out (Environment Agency, 2014) a process for developing prioritised routine and emergency asset monitoring. Bath & North East Somerset Council’s Local Flood Risk Management Strategy (Bath & North East Somerset Council, 2015)

If national and local guidance is adopted, flood risk should not increase as a result of new development. There will occasionally be situations where development in the floodplain is unavoidable or where, when all things are considered, the risks posed are outweighed by very significant environmental and socio-economic benefits. It is important in these circumstances to be able to demonstrate no detrimental impact on downstream impacts and that new development will remain safe through resilience and resistance measures. The Lead Local Flood Authority will review this as part of the application process. It is therefore important that developers follow national and local guidance and seek advice from the Lead Local Flood Authority as needed to ensure the right information is provided as part of a planning application.

4.5.3 Asset deterioration and/or blockage Unless maintained, deterioration will occur in the condition and performance of existing drainage infrastructure and flood defence structures. As a result an 46 Bath & North East Somerset Local Flood Risk Management Strategy

4.6 Communities most at risk from local flooding A number of ‘wet-spots’ were identified in the Bath & North East Somerset regional Surface Water Management Plan. These were derived from analysis of recent and relevant flood incident data, and verified through an analysis of the predicted surface water flood risk areas identified by the Updated Flood Map for Surface Water. In total 53 individual wet-spots were identified. In every wet-spot a suitable action was identified in the Bath & North East Somerset regional Surface Water Management Plan, and has been transposed into this Local Flood Risk Management Strategy to form the actions the Lead Local Flood Authority will take, in partnership with others, to manage local flood risk. Section 5.2 and Appendix D provide further information on these actions. Bath & North East Somerset Local Flood Risk Management Strategy 47

Figure 4-3 Overview of the Interactive Map of Local Flood Incidents, taken from the Surface Water Management Plan

DRAINAGE AREAS FLOOD RISK LAYERS DA01 Blagdon Lake FLOOD FREQUENCY PFRA Flood Risk Area Number of Flooding Number of DA02 Chew Magna & Chew Stoke (Note: This area is addressed within the Incidents public Sewer Flooding Incidents DA03 Bishop Sutton & West Harptree Bristol SWMP) 1 DA04 East Harptree & Coley 2 - 3 1 - 2 DA05 Whitchurch 4 - 5 3 - 4 DA06 Pensford & Publow 6 - 7 5+ DA07 High Littleton & Clutton 8 - 10 DA08 Keynsham & Saltford DA09 Marksbury & Chewton Keynsham

DA10 Paulton, Timsbury & Farmborough

DA11 Midsomer Norton & Radstock DA12 Bath Rural North DA12 DA13 Bath Rural West DA08 DA18 DA14 Bath Rural South West DA05 DA15 Wellow & Hinton Charterhouse DA16 City of Bath DA13 DA16 DA17 Bath Rural South East DA09 DA18 Bath Rural East DA06 DA02 MAPPING LAYERS ✔ B&NES boundary DA17 DA14 ✔ Drainage Areas

FLOOD INCIDENT LAYERS From 2009 to 2014 DA01 DA03 DA10 ✔ Fluvial: ordinary watercourse DA15 DA07 ✔ Surface Water: drainage ditch

✔ Surface Water: highway gulley DA04 ✔ Surface Water: pluvial runoff

✔ Surface Water: highway culvert DA11

✔ Unknown ✔ Fluvial Interactions B&NES DRAINAGE AREAS Surface Water: public sewer Flood Incident Map ✔ (2013-2014) Date of Plot: 22 July 2015 (Note: Flooding records represented by 0 2.5 5 7.5 10 Contains Ordnance Survey data. postcode area) Kilometres © Crown copyright and database right 2015 48 Bath & North East Somerset Local Flood Risk Management Strategy Section 5 Action Plan 50 Bath & North East Somerset Local Flood Risk Management Strategy

This section sets out the actions the Lead Local Flood Authority will take, in 5.1 The Strategy Action Plan partnership with others, to manage local flood risk. Measures already being The Strategy Action Plan measures are identified in Table 5-1 and are broken delivered are outlined in Section 3. Actions that the Lead Local Flood Authority down by the objectives set out in Section 2. These are repeated below for will take across Bath & North East Somerset (‘Strategy Action Plan’) are reference: outlined in Section 5.1, and location-specific actions are identified in Section 5.2. • Objective 1: improve understanding of local flood risk; The delivery of actions in the Local Flood Risk Management Strategy will be • Objective 2: promote community awareness and build capability for dependent upon the availability of funding. Therefore a phased implementation appropriate action; will be required. The actions are also subject to legislative, regulatory • Objective 3: manage local flood risk through capital and maintenance and financial changes during the ten year period of the Local Flood Risk investment; Management Strategy and the Council needs to maintain some flexibility during the delivery period. The Lead Local Flood Authority will update the • Objective 4: prevent inappropriate development that creates or increases action plan annually, and this update will identify these changes and the effect flood risk; on the Local Flood Risk Management Strategy actions. • Objective 5: improve flood preparedness, warning and ability to recover. The Strategy Action Plan includes measures which are currently underway, but also includes new measures which are necessary to ensure the delivery of the objectives outlined. It is a ‘live’ document which the Lead Local Flood Authority will update as part of the annual review of the action plan. Bath & North East Somerset Local Flood Risk Management Strategy 51

Objectives

For reference, Table 5-1 is broken down into the following columns:

Ref: This column provides the unique Action: This column provides a description of the Expected Outcome/Indicator for Success: This reference for each action included specific actions which have been developed to column provides a description of the desired outcome, or within this Strategy Action Plan. help ensure each strategy objective is achieved. the indicator for success, following implementation of the action.

Table 5-1 Strategy Action Plan Stage at August 2015: Objective 1 – Improve understanding of local flood risk The stage number indicates Ref: LFRMS – 1a Action Stage at August 2015: 3 progress against this action Complete a regional Surface Water Management Plan. Link with Surface Water Management Action Owner: Lead Local Flood and refers to the ‘Stages to Plan Action/s: NA Expected Outcome/ Indicator for Success Authority* A fuller understanding of the local sources of flood risk in Bath & North East Achieve Action’ section of Action Supporter: Strategic Flood Somerset based on recorded and modelled flood risk information from multiple Board agencies. the table. Priority: Complete Stages to Achieve Action 1. Collate, analyse and map recent and relevant flood incidents from project Action Owner: This sets Link with Surface Water Management partners to fully understand the flood risk in Bath & North East Somerset. out who is responsible Plan Action/s: This column provides the 2. Prioritise key flooding locations or ‘wet spots’. 3. Produce a long term, area wide plan to manage local sources of flooding within for overseeing the unique reference, where appropriate, of Bath & North East Somerset. This includes two action plans; implementation of each actions developed as part of the Bath & 1). A strategic and operational action plan which has been merged into this Local Flood Risk Management Strategy Action Plan, and action. North East Somerset regional Surface 2). a Location Specific Action Plan provided in Appendix D. Water Management Plan. These have Action Supporter: This now been incorporated into, and will be column sets out who else delivered as part of, this Strategy Action will be involved, in addition to Plan. The wording of the actions may be the action owner, to support slightly different to that provided in the implementation of the action. Bath & North East Somerset regional Surface Water Management Plan, but the Stages to Achieve Action: This column Priority: The priority of each action has been assigned as principles will be addressed through the sets out the stages considered necessary to high, medium or low. This does not necessarily mean the implementation of the ‘Stages to Achieve successfully achieve the action and meet the actions will be undertaken in this order, but just that some Action’ plan. expected outcome/ indicator for success. actions are deemed to be a greater priorities than others. 52 Bath & North East Somerset Local Flood Risk Management Strategy

Table 5-1 Strategy Action Plan Objective 1 – Improve understanding of local flood risk

Ref: LFRMS – 1a Action Stage at August 2015: 3 Complete a regional Surface Water Management Plan. Link with Surface Water Management Action Owner: Lead Local Flood Plan Action/s: NA Expected Outcome/ Indicator for Success Authority* A fuller understanding of the local sources of flood risk in Bath & North East Action Supporter: Strategic Flood Somerset based on recorded and modelled flood risk information from multiple Board agencies. Priority: Complete Stages to Achieve Action 1. Collate, analyse and map recent and relevant flood incidents from project partners to fully understand the flood risk in Bath & North East Somerset. 2. Prioritise key flooding locations or ‘wet spots’. 3. Produce a long term, area wide plan to manage local sources of flooding within Bath & North East Somerset. This includes two action plans; 1). A strategic and operational action plan which has been merged into this Local Flood Risk Management Strategy Action Plan, and 2). a Location Specific Action Plan provided in Appendix D. Ref: LFRMS – 1b Action Stage at August 2015: 4 Continue to develop an updated flood reporting system. Link with Surface Water Action Owner: Lead Local Flood Management Plan Action/s: Expected Outcome/ Indicator for Success Authority SOAP01 Flood incident data provided in a standardised format which will improve ability Action Supporter: Council Connect, to use the data as a beneficial source of information. Local Highways Authority, Environment Stages to Achieve Action Agency, Wessex Water, Avon Fire and Rescue. 1.  Review the Surface Water Management Plan database summarising flooding to understand key information. Priority: High 2. Review Bath & North East Somerset flood incident reporting system. 3.  Update the reporting system to include prompts for key information. Information to include; date, location, duration, an idea of the flood source, description of the flood extent and depth. 4. Undergo annual review of the flood reporting system and update as appropriate.

* Lead Local Flood Authority: Bath & North East Somerset Council’s Drainage and Flooding Team undertake most of these responsibilities. Bath & North East Somerset Local Flood Risk Management Strategy 53

Objective 1 – Improve understanding of local flood risk

Ref: LFRMS – 1c Action Stage at August 2015: 3 Link with Surface Water Management Improve the use of visual tools (e.g. GIS) to record and analyse flooding Action Owner: Lead Local Flood Plan Action/s: NA incidents. Authority, Bath & North East Somerset Expected Outcome/ Indicator for Success GIS team. A holistic picture of flooding in the region and improved ability to identify priority Action Supporter: Environment areas in the future. Agency, Wessex Water Stages to Achieve Action Priority: Medium 1. Identify and map flooding incidents as part of theBath & North East Somerset

regional Surface Water Management Plan. 2. Develop a process to add new flooding incidents to GIS when they occur. 3. Incorporate flooding incidents to the GIS.

Ref: LFRMS– 1d Action Stage at August 2015: 1 Continue to complete investigations of flood incidents, where the Link with Surface Water Management Action Owner: Lead Local Flood appropriate criteria is met (see Section 3.4.6). Plan Action/s: NA Authority Expected Outcome/ Indicator for Success Action Supporter: Relevant Risk The appropriate Risk Management Authority is identified, and an investigation is Management Authorities. completed Priority: High (following flood events Stages to Achieve Action which meet the criteria) 1. Lead Local Flood Authority to identify the relevant authority responsible for undertake a Section 19 investigation where the criteria is met.

Ref: LFRMS– 1e Action Stage at August 2015: 2 Ensure that appropriate data on flooding is shared between organisations, Link with Surface Water Management Action Owner: Lead Local Flood and between organisations and communities. Plan Action/s: NA Authority Expected Outcome/ Indicator for Success Action Supporter: Relevant Risk Awareness about flood risk is improved within Bath & North East Somerset. Management Authorities, communities, Stages to Achieve Action other organisations 1. Ensure Risk Management Authorities share appropriate data about flooding with Priority: Medium the Lead Local Flood Authority. (Links specially with LFRMS 1a & 3a). 2.  Ensure communities and other organisations can share knowledge about flooding with the relevant Risk Management Authority. (Links specially with LFRMS 2a, 2b & 2d). 3.  Ensure relevant flooding information obtained through stages 1 and 2 above is shared appropriately with communities in Bath & North East Somerset 54 Bath & North East Somerset Local Flood Risk Management Strategy

Objective 2 – Promote community awareness and build capability for appropriate action

Ref: LFRMS– 2a Action Stage at August 2015: 1 & 2 Establish clearer routes for communicating with communities and Link with Surface Water Management Action Owner: Lead Local Flood businesses about the roles and responsibilities for flood risk. Plan Action/s: NA Authority Expected Outcome/ Indicator for Success Action Supporter: Parish Good communication will enable people to clearly understand their risks, the impact councils, Wards, Federation of Bath of proposed actions to manage these risks, and what can be done by communities Residents Association, Local Flood and businesses to manage the residual risk. Representatives, Environment Agency, Stages to Achieve Action Wessex Water 1. Agree routes for communication between communities, the Operational Flood Priority: Medium Working Group, Local Flood Representatives and other appropriate partners. 2. Raise awareness of ways to report property flooding and communicate about other appropriate flooding information. Ref: LFRMS– 2b Action Stage at August 2015: – Help communities understand their own flood risk and their responsibilities Link with Surface Water Management Action Owner: Lead Local Flood for managing flooding. Plan Action/s: NA Authority, Emergency Planning and Expected Outcome/ Indicator for Success Business Continuity Improved awareness within communities about responsibilities around managing Action Supporter: Local Flood flooding and how to assess flood risks. Representatives Parish Councils, Stages to Achieve Action Wards, Community Groups, 1. Work with partners to support community-led flood forums or flood awareness Environment Agency Wessex Water events. Priority: High

Ref: LFRMS– 2c Action Stage at August 2015: – Raise awareness of land drainage and riparian responsibilities. Link with Surface Water Management Action Owner: Lead Local Flood Plan Action/s: NA Expected Outcome/ Indicator for Success Authority Improved maintenance of watercourses by Riparian Owners Action Supporter: Local Flood Stages to Achieve Action Representatives, other appropriate 1. Work with Local Flood Representatives, or other appropriate partners, to ensure partners awareness riparian responsibilities is improved amongst communities. Priority: Medium Bath & North East Somerset Local Flood Risk Management Strategy 55

Objective 2 – Promote community awareness and build capability for appropriate action

Ref: LFRMS– 2d Action Stage at August 2015: 2 Develop a network of Local Flood Representatives to act as a point of Link with Surface Water Management Action Owner: Lead Local Flood contact in the community on flooding issues. Plan Action/s: SOAP 08 Authority Expected Outcome/ Indicator for Success Action Supporter: Parish Improved communication between individual communities and the Lead Local Councils, Wards, Federation of Bath Flood Authority on flooding issues. Residents Association, Local Flood Stages to Achieve Action Representatives 1. Invite Parish Councils, the Federation of Bath Residents’ Associations and Bath Priority: Medium Wards to nominate Local Flood Representatives as a communication channel between the Operational Flood Working Group and all communities. 2. Appoint Local Flood Representatives. 3. Continue to review Local Flood Representatives and recruit as needed. Ref: LFRMS – 2e Action Stage at August 2015: 1 Ensure communities know what to do in the event of a flood. Link with Surface Water Management Action Owner: Lead Local Flood Plan Action/s: NA Expected Outcome/ Indicator for Success Authority Communities can approach the appropriate Risk Management Authority for support Action Supporter: Local Flood and are able to recover more quickly as a result of actions taken. Representatives, Councillors Stages to Achieve Action Priority: Medium 1. Develop a guidance sheet to improve awareness of what communities should do in the event of a flood. 2. Share this guidance sheet with Councillors and communities through the appropriate communication channels established as part of LFRMS 2a. 56 Bath & North East Somerset Local Flood Risk Management Strategy

Objective 3 – Manage local flood risk through capital and maintenance investment

Ref: LFRMS – 3a Action Stage at August 2015: 2 Continue to work with partners, including adjacent authorities, to develop Link with Surface Water Management long term approaches to manage flood risk. Action Owner: Lead Local Flood Plan Action/s: SOAP03 & SOAP04 Authority. Expected Outcome/ Indicator for Success A more coordinated approach to the management of local flood risk in Bath & North Action Supporter: Strategic Flood East Somerset. Board, Operational Flood Working Group. Stages to Achieve Action Priority: High 1. Form a Strategic Flood Board and Operational Flood Working Group. 2. Schedule regular meetings of the Strategic Flood Board, and Operational Flood Working Group as required.

Ref: LFRMS – 3b Action Stage at August 2015: 1 Deliver the actions in the regional Surface Water Management Plan. Link with Surface Water Management Action Owner: Lead Local Flood Plan Action/s: NA Expected Outcome/ Indicator for Success Authority, Local Highways Authority. Improved local flood risk in the Bath & North East Somerset. Action Supporter: Strategic Flood Stages to Achieve Action Board, Operational Flood Working 1. Use the findings from the regional Surface Water Management Plan to inform the Group. need for projects/ schemes. Priority: High 2. Work with the Strategic Flood Board, and Operational Flood Working Group, to help deliver this as part of a long term plan.

Ref: LFRMS – 3c Action Stage at August 2015: 1 Continue to develop a register of assets which significantly affect local Link with Surface Water Management Action Owner: Lead Local Flood flood risk. Plan Action/s: SOAP05 Authority. Expected Outcome/ Indicator for Success Action Supporter: Strategic Flood Effective management of assets which have a significant effect on flood risk Board, Bath & North East Somerset Stages to Achieve Action GIS team, Local Highway Authority. 1. Develop an improved flood risk asset register and record template, a process Priority: Medium for the assessment of assets, and establish a periodic monitoring procedure for further discussion. 2. Strategic Flood Board to agree the register and record template, and the assessment and monitoring procedures. 3. Produce the agreed updated flood risk asset register and record. 4. Record and monitor assets using the agreed procedures. Bath & North East Somerset Local Flood Risk Management Strategy 57

Objective 3 – Manage local flood risk through capital and maintenance investment

Ref: LFRMS – 3d Action Stage at August 2015: 1 Designate structures that effect local flood risk, to protect them from Link with Surface Water Management alteration or removal. Action Owner: Lead Local Flood Plan Action/s: NA Authority Expected Outcome/ Indicator for Success Significant assets will not be altered, removed or replaced without consideration Action Supporter: Relevant partners of the impacts to flood risk. This will also enable the Lead Local Flood Authority to Priority: Low understand who owns and maintains structures. Stages to Achieve Action 1. Using the procedure identified for the identification of flood risk assets (Action 3c), identify 3rd party assets. 2. Implement individual procedures on a case by case basis.

Ref: LFRMS– 3e Action Stage at August 2015: 1 Continue to assess applications for works on Ordinary Watercourses, Link with Surface Water Action Owner: Lead Local Flood through the land drainage consent process. Management Plan Action/s: NA Authority. Expected Outcome/ Indicator for Success Action Supporter: Local Planning To ensure the normal flow of water in Ordinary Watercourses with no increase in Authority. flood risk Priority: Medium Stages to Achieve Action 1. Use consenting and enforcement powers when required 2. Raise awareness of Land Drainage Consent via Planning and other means.

Ref: LFRMS – 3f Action Stage at August 2015: 1 Identify catchments where improved land management could reduce flood Link with Surface Water Management Action Owner: Lead Local Flood risk and/ or improve the water environment. Plan Action/s: See the Location Authority. Specific Action Plan for wet spots Expected Outcome/ Indicator for Success Action Supporter: Relevant partners provided in Appendix D Reduced local flood risk and improved overall water environment (e.g. contribution to meeting Water Framework Directive) Priority: Medium Stages to Achieve Action 1. Monitor flooding incidents recorded in wet spots identified in the Bath & North East Somerset regional Surface Water Management Plan to identify catchments where improved land management could reduce flood risk, and work with other organisations to help identify potential areas. 2. If improved land management is deemed as preferable in order to reduce flood risk or improve the water environment, investigate opportunities to work with landowners to develop schemes. 58 Bath & North East Somerset Local Flood Risk Management Strategy

Objective 3 – Manage local flood risk through capital and maintenance investment

Ref: LFRMS – 3g Action Stage at August 2015: 1 Identify critical highway drainage assets, in order to undertake targeted Link with Surface Water Management Action Owner: Lead Local Flood maintenance and respond to issues as the Local Highways Authority. Plan Action/s: SOAP06 Authority, Local Highways Authority. Expected Outcome/ Indicator for Success Action Supporter: – More effective management of highways drainage assets to mitigate/ reduce flood risk. Priority: High Stages to Achieve Action 1. Investigate highways drainage flooding events to identify the critical assets. 2. Develop a revised maintenance regime for these critical assets; or identify assets that require replacement or improvement.

Ref: LFRMS – 3h Action Stage at August 2015: 1 Prioritise maintenance and clearance works to culverts and watercourses. Link with Surface Water Management Action Owner: Lead Local Flood Plan Action/s: NA Expected Outcome/ Indicator for Success Authority More targeted and effective management of culverts and watercourses which pose Action Supporter: Riparian Owners, a significant flood risk. Bath & North East Somerset Ecology Stages to Achieve Action Team, Natural England. 1. Identify and prioritise which culverts or watercourse pose the most significant Priority: High flood risk to people, property and infrastructure 2. Develop a revised maintenance regime for these critical assets; or identify assets that require replacement or improvement. Ensure that consideration is given to the potential impact on roosting bats or other ecology.

Ref: LFRMS – 3i Action Stage at August 2015: 1 Evaluate flood reports to identify where drainage improvements or other Link with Surface Water Management Action Owner: Lead Local Flood mitigation works are possible. Plan Action/s: NA Authority Expected Outcome/ Indicator for Success Action Supporter: Relevant partners Improved drainage/ flood risk. Priority: High Stages to Achieve Action 1. Identify locations and investigate flood mechanisms. 2. Prioritise locations using a risk based approach. 3. Design schemes. 4. Implement schemes where possible. Bath & North East Somerset Local Flood Risk Management Strategy 59

Objective 4 – Prevent inappropriate development that creates or increases flood risk

Ref: LFRMS – 4a Action Stage at August 2015: 1 Continue to review planning applications to make recommendations for Link with Surface Water Management surface water drainage and managing flood risk. Action Owner: Lead Local Flood Plan Action/s: SOAP02 Authority, Local Planning Authority*, Expected Outcome/ Indicator for Success Environment Agency. Planning decisions are properly informed about flood risk and drainage requirements. Action Supporter: Wessex Water, Canal & River Trust Emergency Stages to Achieve Action Planning Authority 1. Ensure new developments consider all flood risk and climate change. Promote Priority: High Sustainable Drainage Systems in accordance with National Planning Policy Framework, the Bath & North East Somerset Place Making Plan, West of England Sustainable Drainage Systems Guidance and other relevant sustainable drainage requirements. Ref: LFRMS – 4b Action Stage at August 2015: 2 Publish the West of England Sustainable Drainage System Guidance Link with Surface Water Management Action Owner: Lead Local Flood for developers, and work across the West of England to co-ordinate Plan Action/s: NA Authority, Local Planning Authority. sustainable drainage system implementation. Action Supporter: West of England Expected Outcome/ Indicator for Success Partnership. Developers utilise sustainable methods of surface water drainage and increases in surface water flow from future development are mitigated. Priority: High Stages to Achieve Action 1. Complete the West of England Sustainable Drainage Systems Guidance document. 2. Publish the guidance on the Bath & North East Somerset Council website and ensure this is communicated to developers as appropriate.

* LPA: Bath & North East Somerset Council/ Local Planning Authority 60 Bath & North East Somerset Local Flood Risk Management Strategy

Objective 4 – Prevent inappropriate development that creates or increases flood risk

Ref: LFRMS – 4c Action Stage at August 2015: 1 Include Sustainable Drainage System planning policy within the Council’s Link with Surface Water Management Action Owner: Local Planning Placemaking Plan/ Core Strategy. Plan Action/s: NA Authority, Lead Local Flood Authority Expected Outcome/ Indicator for Success Action Supporter: – Sustainable drainage is incorporated into new development to reduce surface water runoff and minimise its contribution to flooding. Priority: High Stages to Achieve Action 1. Incorporate Sustainable Drainage System planning policy within the Council’s Placemaking Plan/ Core Strategy.

Ref: LFRMS – 4d Action Stage at August 2015: 1 Continue to provide guidance at the pre-application stage on flooding Link with Surface Water Management Action Owner: Lead Local Flood issues. Plan Action/s: NA Authority, Local Planning Authority. Expected Outcome/ Indicator for Success Action Supporter: Environment Drainage and flooding issues are adequately considered prior to applications gaining Agency, Wessex Water. approval and that applications consider the use of Sustainable Drainage Systems. Priority: High Stages to Achieve Action 1. Work with developers and the Local Planning Authority to implement the most appropriate drainage strategy for planning applications. 2. Promotion of advisory service via Council communication channels and Local Flood Representatives.

Ref: LFRMS – 4e Action Stage at August 2015: 1 Consider the need for additional planning guidance on flooding specific to Link with Surface Water Management Action Owner: Lead Local Flood Bath & North East Somerset. Plan Action/s: NA Authority, Local Planning Authority. Expected Outcome/ Indicator for Success Action Supporter: – Effective planning guidance on flooding is provided within Bath & North east Somerset. Priority: Low Stages to Achieve Action 1. Continually review the appropriateness and effectiveness of current planning guidance to minimise flooding in Bath & North East Somerset. 2. Take appropriate action to improve planning guidance and considered necessary. Bath & North East Somerset Local Flood Risk Management Strategy 61

Objective 4 – Prevent inappropriate development that creates or increases flood risk

Ref: LFRMS – 4f Action Stage at August 2015: 1 Identify areas that are sensitive to surface water flood risk and develop Link with Surface Water Action Owner: Lead Local Flood appropriate surface water drainage and flood risk requirements for any Management Plan Action/s: NA Authority proposed development in these areas. Action Supporter: Local Planning Expected Outcome/ Indicator for Success Authority To ensure flood risk is not compromised and potentially improved with any proposed development. Priority: Medium Stages to Achieve Action 1. Identify development sensitive areas. 2. Develop appropriate drainage and/or flood risk requirements. 62 Bath & North East Somerset Local Flood Risk Management Strategy

Objective 5 – Improve flood preparedness, warning and ability to recover

Ref: LFRMS – 5a Action Stage at August 2015: 1 Help develop a multi-agency flood plan for high risk areas in Bath & North Link with Surface Water Management Action Owner: Emergency Planning East Somerset. Plan Action/s: NA Authority Expected Outcome/ Indicator for Success Action Supporter: Strategic Flood A joined up approach that ensures resources are effectively managed. Board Stages to Achieve Action Action Supporter: Emergency 1. Identify areas at high risk. Services, Environment Agency, Lead 2. Work with partners and communities to produce plans. Local Flood Authority. 3. Share the flood plan with communities in the region using the agreed approach Priority: Medium developed in LFRMS 2a.

Ref: LFRMS – 5b Action Stage at August 2015: 1 Communicate information to communities, businesses and individuals on Link with Surface Water Management Action Owner: Lead Local Flood flood preparedness and recovery. Plan Action/s: NA Authority, Emergency Planning Expected Outcome/ Indicator for Success Authority. Communities, individuals and businesses can adequately prepare for flooding and Action Supporter: Environment are more likely to be able to recover more quickly following a flood event. Agency, Parish Councils, Community Stages to Achieve Action Groups, Local Flood Representatives. 1. Work with Local Flood Representatives, or other appropriate partners, to target Priority: High the most vulnerable communities, businesses and individuals as outlined in the Bath & North East Somerset regional Surface Water Management Plan / those interested in developing their own Community Flood Plans. 2. Provide literature and templates to ensure plans are appropriately structured, developed and maintained. Bath & North East Somerset Local Flood Risk Management Strategy 63

Objective 5 – Improve flood preparedness, warning and ability to recover

Ref: LFRMS – 5c Action Stage at August 2015: 1 Promote uptake of the Environment Agency’s Floodline Warnings Direct Link with Surface Water Management Action Owner: Lead Local Flood service. Plan Action/s: NA Authority, Communications team. Expected Outcome/ Indicator for Success Action Supporter: Environment Individuals will have improved access to flood warnings which will aid them in their Agency. ability to respond to threats. Priority: Low Stages to Achieve Action 1. Review information provided on the Bath & North East Somerset Council website and update as appropriate. Ensure consideration is also given to providing information about the service on appropriate Council literature and other communications.

Ref: LFRMS – 5d Action Stage at August 2015: 1 Improve warnings and proactive mitigation in response to predicted Link with Surface Water Action Owner: Lead Local Flood rainfall. Management Plan Action/s: Authority. SOAP07 Expected Outcome/ Indicator for Success Action Supporter: Local Highways Assets can be targeted for maintenance in advance of forecast rainfall to reduce Authority, Emergency Planning and the risk of blockage, and hence flood risk. Business Continuity, Met Office. Stages to Achieve Action Priority: High 1. Develop a timely and appropriate response to flood and serve weather warnings; giving consideration for proactively maintaining assets in response to forecast rainfall. 64 Bath & North East Somerset Local Flood Risk Management Strategy

5.2 Location-Specific Action Plan A significant number of the wet-spots identified in the Bath & North East Somerset regional Surface Water Management Plan (42 of the 53 identified The Bath & North East Somerset regional Surface Water Management Plan is in total) had common actions around improvements to highway and/or land the most comprehensive source of information about location-specific actions. drainage, and have been grouped together in the Bath & North East Somerset It contains at least one action for each of the wet-spots identified as being regional Surface Water Management Plan and Local Flood Risk Management vulnerable to surface water flood risk based on recent and relevant flooding Strategy. For these wet-spots a five stage implementation plan was identified incidents and predicted flood risk. For the Local Flood Risk Management in the Bath & North East Somerset regional Surface Water Management Plan: Strategy the Location Specific Action Plan has been transposed from the Bath & North East Somerset regional Surface Water Management Plan. This is a 1. monitor; ‘live’ action plan which will be updated as measures are implemented or new 2. check cyclic maintenance has been carried out; information becomes available following further inspections or investigations. It will be reviewed on an annual basis. 3. investigate performance of highway/land drainage system, identifying any maintenance or design requirements; This Location Specific Action Plan recommends measures to investigate, reduce or mitigate local flood risk in Bath & North East Somerset, and 4. carry out required maintenance or design and construct engineering developed so it can be delivered in a phased approach. In many locations the scheme, and; action plan recommends further investigation or survey in the first instance. 5. implement continued maintenance programme. This is necessary to fully understand flooding mechanisms and impacts prior to the development of flood mitigation schemes. The 42 wet-spots identified in the Bath & North East Somerset regional Surface Water Management Plan which have been grouped together with common actions are listed in Table 5‑2. Further details on the action owner, priority and indicative cost are provided in Appendix D. Bath & North East Somerset Local Flood Risk Management Strategy 65

Table 5-2 Action plan with common actions for highway/land drainage improvements

Wet-spot Location Wet-spot Location ID ID DA06A Publow Lane and Pensford Hill DA16I Priory Park Road, Wiscombe DA07B Wells Road, Hallatrow DA09A Redlynch Lane, Chewton, Keynsham DA07C Rush Hill, Farrington DA12A Bath Road, Kelston DA10C Durcott Lane, Camerton and Radford DA13A Wells Road, Corston DA10D Brookside Paulton DA14B Tunley Road, Longhouse DA11A Hayes Park area, Midsomer Norton DA16A Weston and Upper Weston DA11D Fortescue Road, Radstock Regeneration area DA16C Newbridge Road DA14A Vicinity of Crossways, Dunkerton DA01A Ubley, Blagdon Lake DA16B Charlcombe Lane and London Road, Larkhall DA03A Wick Road and Ham Lane, Bishop Sutton and Fairfield DA16E Camden Crescent, Walcot DA04A South Widcombe DA16F Bathwick Street, Bathwick DA04B Coley DA16H Lymore Avenue, South Twerton DA07A Clutton Hill DA16J Wellsway, Bloomfield DA08C Bath Road, Saltford DA03B Bristol Road, Whitecross Farm DA11C Fosse Way, Clandown DA05A Bristol Road, Whitchurch DA11E Kilmersdeon Road, Haydon DA06B Charlwood DA13B Pennyquick, Newton St Loe DA08A Park Road, Keynsham DA15A Old Milford Road, Twinhoe DA10A The Street, Farmborough DA15B The High St, Wellow DA10E Carlingcott Lane DA15C Green Lane, Hinton Charterhouse DA10F Bath Road & Albert Avenue, Peasdown St John DA17A Brassknocker Hill, Monkton Combe DA11B Charlton Road, Midsomer Norton DA18A Box Road and London Road East, Batheaston and Bathford 66 Bath & North East Somerset Local Flood Risk Management Strategy

In addition, 14 wet-spots identified in the Bath & North East Somerset 5.3 Maximising the wider benefits of flood risk management regional Surface Water Management Plan have been assigned specific Flood risk management intervention can offer a significant range of wider actions. In these wet-spots the actions are bespoke to each area, and range benefits beyond reducing flood risk. For example, it can: from inspection and investigation, through to scheme design and build. The following wet-spots have specific actions identified: • protect or enhance the environment by improving water quality, hydromorphology of watercourses, creating habitat or new biodiversity; • Bath City Centre; • provide amenity for local communities; • Batheaston and Bathford; • ensure areas with historical importance and value can be better protected; • Chew Magna; • improve mental and physical health through reduction of the stress • Chew Stoke; associated with flood risk, and creation of new amenity features integrated • Clandown; into the design of a scheme; • West Harptree; • support economic regeneration, and; • Whitchurch; • unlock additional land for future development. • Keynsham; Historically, drainage and flood risk management infrastructure have • Lower Bristol Road; been designed and implemented with limited focus on the wider social, environmental or economic benefits. Through implementation of the Local • Timsbury; Flood Risk Management Strategy actions the Lead Local Flood Authority will • Midsomer Norton; encourage and promote investment in drainage and flood risk management which integrates wider social, economic and environmental benefits into • Weston and Upper Weston; design and implementation. • Weston Village; Indeed, to access many funding sources the Lead Local Flood Authority • Weston Park, and; will need to demonstrate the wider benefits of our investment. The Lead Local Flood Authority will therefore need to think carefully during design and • White Cross Farm (Bristol Road). implementation to maximise the wider social, economic and environmental Across these 14 wet-spots 21 specific actions have been identified (i.e. a benefits of our investment, which in turn will support access to funding. few wet-spots have more than 1 specific action). 17 of these actions are This can only be achieved through close partnership working and early considered high priority in the Bath & North East Somerset regional Surface consideration of the wider opportunities through investment. For example, Water Management Plan, with a further four considered as medium priority. through implementation of green infrastructure in developed areas which The specific actions for each wet-spot is provided in Appendix D. capture surface water at source, thereby reducing flood risk, but which also provide significant opportunities to improve amenity, and to create habitat and biodiversity within developed areas. Bath & North East Somerset Local Flood Risk Management Strategy 67

5.3.1 Environmentally responsible flood risk management With respect to the Location Specific Action Plan the majority of actions are focused on improvements to highway drainage, inspections and/or There is a range of European and UK legislation which ensures protection investigations. These will have limited, if any, impact on the environment, and enhancement of the environment, such as the Strategic Environment although we will always undertake measures with consideration to the Assessment Directive, the Water Framework Directive and the Conservation surrounding environment. Where location-specific actions identified in the of Habitats and Species Regulation (‘Habitats Regulation’). Any investment Bath & North East Somerset regional Surface Water Management Plan or must not cause detriment to the environment, and should seek enhancement Local Flood Risk Management Strategy interact with a Main River or Ordinary wherever possible. Watercourse they will need to be subject to a Water Framework Directive The Local Flood Risk Management Strategy action plan has been developed assessment23 during implementation. to set policy or process to reduce flood risk, prevent deterioration of Should larger schemes be identified and progressed these will be in line with the environment, and seek enhancement where possible. For example, planning controls, which will include consideration of environmental impact, in the ‘Strategy Action Plan,’ Action 3f is to “identify catchments where and a screening opinion on the need for an Environmental Impact Assessment improved land management could reduce flood risk and/or improve the will be sought from the Local Planning Authority. It is also recognised that an water environment.” Implementation of this measure will reduce flood risk environmental reporting procedure should and will be undertaken to ensure to communities and reduce diffuse pollution from runoff into watercourses. that the Council’s duties under the relevant legislation are met. Another example is our planning policy in the Placemaking Plan about implementation of Sustainable Drainage Systems as part of new development, Further details on environmentally responsible flood risk management is which will reduce flood risk, improve water quality, and deliver amenity benefits available in the Strategic Environmental Assessment Environmental Report for local residents. which is a separate document.

23 The requirements of the Water Framework Directive and actions to achieve Good Ecological Status need to be taken into account in the planning of all new activities, plans or strategies that could affect the water environment. Many of the aims of the Water Framework Directive are relevant to the preparation of local flood risk management schemes, and such schemes also may offer opportunities to help deliver some of the actions identified in relevant River Basin Management Plans. Therefore when we are proposing local flood risk management schemes as part of our Strategy, these schemes will be subject to a Water Framework Directive Assessment where they involve works to ordinary or main watercourses. This assessment will take account of the requirements of the Water Framework Directive and ensure that the scheme proposals do not conflict with the relevant local River Basin Management Plan or undermine the aims of the Water Framework Directive. 68 Bath & North East Somerset Local Flood Risk Management Strategy Section 6 Funding Strategy 70 Bath & North East Somerset Local Flood Risk Management Strategy

Small drainage works can often be funded from Bath & North East Somerset flood risk management”25, intended to promote successful collaboration and Council’s revenue and capital funding streams. Reported flooding incidents partnership funding. are prioritised on a risk analysis basis. In a continued era of austerity the The development of the Strategic Flood Board, Operational Flood Working delivery of flood risk management infrastructure will require new ways of Group and the West of England Local Enterprise Partnership will assist the working and funding across different organisations and stakeholders. The Lead Local Flood Authority in its ability to effectively communicate project Council may also seek to secure other dedicated flood risk management needs to appropriate partners, whether local businesses or Risk Management funding from Government24 where a project is of sufficient magnitude to justify Authorities, to identify funding needs for projects. The role of the Lead Local additional funding or it is likely to qualify for funding. Flood Authority will be to ensure that proposed schemes are financially viable The introduction of partnership funding by the Department for Environment, with respect to whole life costing, to identify who will be best placed to assist Food and Rural Affairs in 2011 for flood and coastal erosion risk management with funding or in kind contributions, and to work with partners to develop projects means that the ability to leverage additional funding contributions appropriate solutions to manage risks. could be the difference between a project going ahead or not. It may be possible for some projects to be fully funded by Flood and Coastal Erosion 6.1 The ‘Strategy’ funding approach Risk Management Grant in Aid (which is the current partnership funding mechanism for capital works provided by the Department for Environment, Figure 6-1 and Figure 6-2 set out the funding sources and approaches Food and Rural Affairs). However, the majority are likely to require for the actions outlined for the Council’s Local Flood Risk Management supplementary funding from a range of sources to make up the total sum Strategy. These separate the approach for funding of capital works (i.e. new needed. infrastructure to reduce flood risk) and maintenance of existing infrastructure. To leverage additional funding will require relationships and the right timing. In addition tailoring the outputs or outcomes of flood risk management 6.1.1 Funding capital works infrastructure is essential to attract a wider range of funding sources. For Figure 6-1 outlines a hierarchical approach to access funding for capital example, a flood storage area not only provides reduced flood risk, but works to alleviate flooding. The Lead Local Flood Authority will seek to secure creates wider benefits such as new amenity, biodiversity and recreation. dedicated funding from Flood and Coastal Erosion Risk Management Grant These wider benefits are often key to unlocking additional funding from non- in Aid and Local Levy in the first instance (Tier 1) where a project is likely to dedicated flood risk management sources (e.g. Heritage or Lottery Funding). qualify for funding. Refer to Appendix E for further details on these types of The following sections provide information on the approaches that will be funding. taken to gain funding for both strategic and individual actions. Appendix E To determine what funding is likely to be available through Flood and expands further on the full range of potential funding opportunities available. Coastal Erosion Risk Management Grant in Aid we will use Department In addition the Department for Environment, Food and Rural Affairs has for Environment, Food and Rural Affairs Partnership Funding Calculator to published a guide to “Partnership funding and collaborative delivery of local identify the amount that is likely to be available through this route and help the

24 This could include Flood and Coastal Erosion Risk Management Grant in Aid funding from Central 25 Partnership funding and collaborative delivery of local flood risk management. Government, or funding from the Regional Flood and Coastal Committee Bath & North East Somerset Local Flood Risk Management Strategy 71

Lead Local Flood Authority to identify the size of the funding gap. The Lead Where a funding shortfall remains, the Lead Local Flood Authority will Local Flood Authority will then engage with the Regional Flood and Coastal subsequently consider Tier 2 funding. This primarily considers economic Committee to identify the likelihood of securing Local Levy. In the majority of growth and/or other direct beneficiaries of the proposed scheme, and may cases funding from these sources will not be sufficient to fully fund a scheme include: (unless it scores >100% on the Department for Environment, Food and Rural • Local authority contributions (either capital or revenue); Affairs Partnership Funding Calculator). It should be recognised that funding from this category is dependent on the benefits the scheme will provide (i.e. • West of England Local Enterprise Partnership where a scheme can directly linked to Department for Environment, Food and Rural Affairs outcomes). contribute towards economic growth; Flood and Coastal Erosion Risk Management Grant in Aid is provided by • Section 106 agreements can be used to support provision of infrastructure the Department for Environment, Food and Rural Affairs, but administered and where they are directly related to development, necessary to make the managed by the Environment Agency. development acceptable, and relevant to planning; Funding is unlikely to meet the full scheme costs in most cases, and approvals • Bath & North East Somerset Community Infrastructure Levy, and; are subject to the consent of the Wessex Regional Flood and Coastal • Beneficiaries of the scheme (e.g. homeowners, businesses or utility Committee. providers). Local Levy can be raised by the Wessex Regional Flood and Coastal For each capital scheme the Lead Local Flood Authority will identify the Committee and used to support flood risk management projects that do not economic growth and development opportunities, and the potential attract 100% national funding through Flood and Coastal Erosion beneficiaries. The Lead Local Flood Authority will also engage with relevant Risk Management Grant-in-Aid. organisations early to identify potential funding, either as a contribution towards a Flood and Coastal Erosion Risk Management Grant in Aid application or a contribution outside of this process. Tier 3 funding is from non-flood risk management sources. To access these will require thinking about the wider benefits such as biodiversity, amenity, health/wellbeing, recreation, and education. Sources could include Lottery funding, money raised by the community and from potential European Union funding sources. Further explanation on these sources of funding is provided in Appendix E.

72 Bath & North East Somerset Local Flood Risk Management Strategy

Figure 6-1 Options for funding of capital flood risk management works. 6.1.2 Funding maintenance of existing infrastructure Most of the responsibility for funding of maintenance lies with the Risk Management Authority responsible for the asset (as explained in Section 3.3.2), but Riparian Owners (explained in Section 3.4.3) also have Tier 1: Flood Risk • Flood and Coastal Erosion Risk responsibilities for funding maintenance along watercourses which form part Management Management Grant in Aid of the land they own. • Local Levy As highlighted in Figure 6-2 this means that Wessex Water are responsible • Revenue funding for Lead Local Flood for funding maintenance of sewer network assets that they are responsible Authority and funding for statutory consultee for. The money for this comes from the revenue they gain from charging their role for surface water drainage customers for the services they provide. • One off grants, such as repair and renew With respect to roads the responsibility for maintenance depends on the grants asset owner. Funding for maintenance of the assets we are responsible for comes predominantly from revenue through the Council’s Settlement Funding Tier 2: Economic • Local Authority Capital & Revenue Funding Assessment and Council Tax. Funding for the Highways England comes via growth and • Development and economic growth the Department for Transport. beneficiaries sources (e.g. Local Enterprise Partnership, Maintenance of Main Rivers (and associated structures) is the responsibility of S.106, or Community Infrastructure Levy) Riparian Owners and/or the Environment Agency, depending on ownership. • Beneficiaries of the scheme In some cases the Environment Agency will undertake maintenance of Main (e.g. homeowners, businesses Rivers which are under Riparian Ownership, using their permissive powers to or utility providers) manage flood risk under the Water Resources Act (1995). Funding for work undertaken by the Environment Agency comes from central government. • Third party funding (e.g. European, lottery Tier 3: Non Flood Similarly, maintenance of Ordinary Watercourses is the responsibility of or community fundraising) Risk Managament Riparian Owners. Using permissive powers under the Land Drainage Act Sources (1991) the Lead Local Flood Authority proactively maintain 37 reaches of Ordinary Watercourses and reactively maintain trash screens, to reduce property flood risk. Funding for the Council’s maintenance work comes predominantly from revenue through our Settlement Funding Assessment and Council Tax. Riparian Owners will need to privately fund their own maintenance works. Bath & North East Somerset Local Flood Risk Management Strategy 73

The Council already compile a yearly maintenance and improvements programme to prioritise where efforts will be focused. This will continue to be undertaken, but using a risk based approach to ensure resources are allocated effectively. This will ensure there is a clearer approach to where the Council plan to focus its attention in the medium term.

Figure 6 2 Funding for maintenance of existing infrastructure

Watercourses Drainage Assets and Structures

Ordinary Sewer Networks Highways Assets Main Rivers Watercourses

Bath and North East Riparian Owners, Riparian Owners, Wessex Water Somerset Council, Environment Agency Bath and North East Highways England Somerset Council 74 Bath & North East Somerset Local Flood Risk Management Strategy Section 7 Governance, Monitoring and Review 76 Bath & North East Somerset Local Flood Risk Management Strategy

7.1 Governance for flood risk management 7.2 Monitoring There is a governance arrangement in place to co-ordinate actions at an Monitoring, reviewing and updating the Local Flood Risk Management operational and strategic level, and ensure that these have appropriate Strategy will be essential to ensure it continues to be ‘fit for purpose’. It will scrutiny and accountability through our Flood Risk Scrutiny Panel, and also demonstrate success in delivering reduced flood risks to communities in Full Council. An overview of the governance arrangements for flood risk Bath & North East Somerset. management, and the interfaces with stakeholders, is provided in Figure 7-1. The Lead Local Flood Authority will monitor the progress of the Local Flood Risk Management Strategy on an annual basis through preparation of the 7.1.1 Resources annual action plan, which will be presented to, and agreed by, the Strategic To ensure Bath & North East Somerset Council can fulfill its duties as a Lead Flood Board. The annual action plan will identify: Local Flood Authority, members of the Drainage and Flooding Team, who • progress against the strategies objectives; carry out most of the responsibilities of this role, are appropriately trained and • whether measures have been delivered and can therefore be removed from experienced. Most team members have completed the Environment Agency’s the action plan; River and Coastal Engineering Degree programme, and the team is overseen by an experienced Flood Authority Manager. • any changes to legislation or understanding of flood risk, and the implications of this, and; This also ensures the Drainage and Flooding Team can provide in-house technical advice to those such as the Planning Policy Team who undertake • set the priorities for the forthcoming year. most of the responsibilities of the Local Planning Authority. The action plan will be published on the Bath & North East Somerset Council website. Bath & North East Somerset Local Flood Risk Management Strategy 77

Figure 7-1 Governance for flood risk management

Working Groups Full Council Organisations

Neighbouring Local Authorities Strategic River Group (Includes River Channel Cladding Project) Scrutiny Panels Avon Fire and Rescue

Development Coordination Group Bristol Water Strategic Flood Board B&NES (various departments) Environment Agency Wessex Water Lead Local Flood Authority River Safety Group Bristol Avon River Trust (Incorporates Avon Fire and Rescue)

Canal and River Trust Bristol Avon Catchment Partnership - Steering Group

Avon and Somerset Police Operational Flood Working Group B&NES Council Highway Maintenance and Drainage, Emergency Planning Environment Agency Wessex Water (relevant) Local Flood Rep.

B&NES Departments Incl. Parish Councils Bath Wards, and Business Public Council Connect (public) FOBRA (Local Flood Rep.) 78 Bath & North East Somerset Local Flood Risk Management Strategy

7.3 Review and Update The Local Flood Risk Management Strategy will remain live for a ten year period to 2025, after which it will be reviewed and updated where necessary. A mid-term update of the Local Flood Risk Management Strategy will take place after five years, in 2020, to check progress against the strategies objectives and update the document where required. The update of the Local Flood Risk Management Strategy in 2020 will be reviewed by the Flood Risk Scrutiny Panel. Any significant changes to the Flood and Water Management Act (which is to be reviewed in 2017) which concern the duties of the Lead Local Flood Authority will be reflected in the 2020 review. In the interim period the Local Flood Risk Management Strategy will only be updated if: • it is not meeting its objectives as identified in the annual action plan; • significant flooding occurs that causes the Lead Local Flood Authority to re- consider the risk assessment and prioritised locations; • there are significant updates to datasets which underpin the risk assessment undertaken in the Bath & North East Somerset regional Surface Water Management Plan; • there are regulatory, policy or legislative changes that affect the roles and responsibilities for flood risk management, or; • there are changes to the funding landscape which affects our ability to meet the Local Flood Risk Management Strategy actions. Appendix A Policies, legislation, plans, assessments and strategies 80 APPENDIX A Bath & North East Somerset Local Flood Risk Management Strategy

Contents

National legislation 81 The Flood and Water Management Act 2010 Flood Risk Regulations 2009 Land Drainage Act 1991 Water Framework Directive Climate Change Act Conservation of Habitats and Species Regulations Civil Contingencies Act Strategic Environmental Assessment Directive National Flood and Coastal Erosion Risk Management Strategy 84 National Planning Policy Framework 84 Plans, Assessments and Strategies undertaken locally by Risk Management Authorities 85 Preliminary Flood Risk Assessment Strategic Flood Risk Assessments Flood Risk Management Strategy Surface Water Management Plans Flood Risk Management Plans Catchment Flood Management Plans Core Strategy Strategic Environmental Assessment Emergency Planning Protocol City of Bath World Heritage Site Management Plan Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX A 81

National legislation The Flood and Water Management Act 2010 To avoid administrative burdens, the Flood and Water Management Act does not require routine reporting on performance, but allows information The Flood and Water Management Act (2010) brings together the to be requested where necessary. Local authorities can bring matters to the recommendations of the Pitt report and previous policies to improve the Government’s attention and if a risk management authority fails to exercise a management of water resources and create a more comprehensive and risk flood or coastal erosion risk management function, the Secretary of State can based regime for managing the risk of flooding from all sources. The Flood direct another authority to carry out that function. In addition, the Flood and and Water Management Act states that its purpose is to “make provision Water Management Act enables Overview and Scrutiny Committees in Lead about water, including provision about the management of risks in connection Local Flood Authorities to hold all the risk management authorities to account. with flooding and coastal erosion”. The key features of the Flood and Water In this way, the public can be actively involved in ensuring authorities perform Management Act in relation to flood and coastal risk management are that it and fulfil their responsibilities. provides: Under the Flood and Water Management Act a ‘flood’ is caused by heavy • the Environment Agency with a strategic overview role of all flood and rainfall; a river overflowing its banks or being breached; a dam overflowing coastal erosion risk management and re-affirms their responsibility as or being breached; tidal waters; groundwater; or anything else including a the lead authority for managing flood risk from Main Rivers, the Sea and combination of factors. It does not include a flood caused from any part of a reservoirs; sewerage system, unless wholly or partly caused by an increase in the volume • unitary Authorities and County Councils with a Lead Local Flood Authority of rainwater (including snow and other precipitation) entering or otherwise role, allocating responsibility for managing flooding from surface runoff, affecting the system; or a flood caused by a burst water main. groundwater and ordinary watercourses; • an improved risk based approach to reservoir safety, and; Flood Risk Regulations 2009 • a duty for relevant flood risk management authorities to co-operate and The Flood Risk Regulations came in to force on 10th December 2009 and share information. transpose the European Commission Floods Directive (Directive 2007/60/EC on the assessment and management of flood risks) into UK domestic law. A key implication for County Councils and Unitary Authorities is the The Flood Risk Regulations can be viewed online. introduction of the Lead Local Flood Authority role, which enhances their responsibilities so that they lead the co-ordination of local flood risk The Directive requires Member States to develop and update a series of tools management in their areas. However, partnership arrangements are in no for managing all sources of flood risk. The Flood Risk Regulations outline way prevented, which will ensure full use of all capabilities and experience the roles and responsibilities of the various authorities consistent with the locally. In addition, the Flood and Water Management Act allows for all roles Flood and Water Management Act and provide for the delivery of the outputs and actions to be delegated to another risk management authority (subject to required by the directive. agreement), with the exception of the Local Flood Risk Management Strategy, which must be developed by the Lead Local Flood Authority. The Flood and Water Management Act is available online. 82 APPENDIX A Bath & North East Somerset Local Flood Risk Management Strategy

The Regulations give responsibility to: Land Drainage Act 1991 • the Environment Agency to prepare Directive deliverables: preliminary The Land Drainage Act (1991) outlines the duties and powers to manage land assessment report, flood risk maps and hazard maps and flood risk drainage for a number of bodies including the Environment Agency, Internal management plans for flood risk from the sea, main rivers and reservoirs; Drainage Boards, local authorities, navigation authorities and riparian owners. • Lead Local Flood Authorities to do the same for ‘local flood risk’, which A number of its provisions have been re-defined following the Flood and Water includes surface runoff, groundwater and ordinary watercourses, and; Management Act, in particular the provisions on consenting and enforcement on ordinary watercourses. As a result Bath & North East Somerset Council • the Environment Agency for collating and publishing the preliminary is now responsible for administering and issuing consents to third parties for assessment reports, flood risk maps and hazard maps, and flood risk undertaking works which could affect ordinary watercourses, and enforcing management plans. where works have been undertaken without the necessary consent, under The stages of the Flood Risk Regulations are illustrated in Figure 1. The Flood Sections 23, 24 and 25 of the Act. Risk Regulations operate on a six yearly cycle; therefore an updated version of the Preliminary Flood Risk Assessment will be prepared in 2017. The Water Framework Directive Preliminary Flood Risk Assessment is a high level screening exercise to identify The Water Framework Directive is the most substantial piece of European areas of most significant flood risk across Europe. The aim of the Preliminary Commission water legislation to date and is designed to improve and integrate Flood Risk Assessment is to assess local flood risk with respect to past floods the way water bodies are managed throughout Europe. It came into force on and the potential harmful consequences of future floods. 22 December 2000 and was transposed into UK law in 2003. Member States must aim to reach good chemical and ecological status in inland and coastal Figure 1 Flood Risk Regulations process (taken from Environment Agency waters by 2015. It is designed to: guidance) • prevent deterioration in the classification status of aquatic ecosystems, protect them and improve the ecological condition of waters; • Preliminary Assessment Report 1 Preliminary Flood • achieve at least good status for all waters. Where this is not possible, good for each LLFA Risk Assessment status should be achieved by 2021 or 2027; • Deadline 22/06/2011 • promote sustainable use of water as a natural resource; 2 Identify Flood • Where the risk of flooding Risk Areas is significant • conserve habitats and species that depend directly on water; • Deadline 22/06/2011 • progressively reduce or phase out releases of individual pollutants or groups of pollutants that present a significant threat to the aquatic environment; 3 Prepare Flood • For Flood Risk Areas Hazard and Flood • progressively reduce the pollution of groundwater and prevent or limit the • Deadline 22/06/2013 Risk Maps entry of pollutants, and; • contribute to mitigating the effects of floods and droughts. 4 Prepare Flood • For Flood Risk Areas Risk Management • Deadline 22/06/2015 Plans Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX A 83

In essence, the Water Framework Directive establishes new and better ways Climate Change Act of protecting and improving rivers, lakes, groundwater, transitional (where The Climate Change Act (2008) requires a UK wide climate change risk freshwater and sea water mix) and coastal waters. To address this, the assessment every five years, accompanied by a national adaptation Environment Agency has embarked on river basin management planning with programme that is also reviewed every five years. The Act has given the the aim to develop new and better ways of protecting and improving the water Government powers to require public bodies and statutory organisations such environment. It should be noted that the objectives referred to above and as water companies to report on how they are adapting to climate change. contained in the Water Framework Directive, whilst supported in the Bath & North East Somerset Local Flood Risk Management Strategy, are considered outside the scope of this Strategy. Nevertheless it is important that measures Conservation of Habitats and Species Regulations to manage local flood risk does not cause deterioration of water bodies and The Conservation of Habitats and Species Regulations (2010) transpose considers opportunities to improve water bodies in conjunction with local the Habitats Directive into UK law. The regulations aim to help maintain flood risk management. and enhance biodiversity throughout the European Union, by conserving River Basin Management Plans have been produced by the Environment natural habitats, flora and fauna. The main way it does this is by establishing Agency for the eleven river basin districts in England and Wales and are a coherent network of protected areas and strict protection measures for the central tool setting out the objectives and actions required to achieve particularly rare and threatened species. the objectives of the Water Framework Directive. River Basin Management Plans describe the main issues for each river basin district and state the Civil Contingencies Act environmental objectives for the basin, explain the objectives selected The Civil Contingencies Act (2004) is legislation that aims to deliver a single to achieve good ecological status and summarise the actions needed to framework for civil protection in the UK and sets out the actions that need deliver those objectives. A River Basin District is: a river basin, or several to be taken in the event of a flood. The Civil Contingencies Act is separated river basins, and the river basin’s adjacent coastal waters. The Severn River into two substantive parts: local arrangements for civil protection (Part 1) and Basin District River Basin Management Plan1 covers the Bath & North East emergency powers (Part 2). Somerset Council boundary, and within the area there are 239 artificial or heavily modified water bodies and 633 natural water bodies. As of 2009 when the Plan was published, only 29% of these were meeting good ecological Strategic Environmental Assessment Directive status. At least 75% of the 40 groundwater bodies were however achieving The Strategic Environmental Assessment Directive (2001) (European good status. As a requirement of the Water Framework Directive all 912 water Commission Directive 2001/42/EC) is legislation which aims to increase the bodies will need to meet good or high ecological status or potential by 2027. consideration of environmental issues during decision making related to strategic documents such as plans, programmes or strategies. The Strategic Environmental Assessment identifies the significant environmental effects that are likely to result due to the implementation of a plan, programme or strategy. A Strategic Environmental Assessment has been prepared in parallel to the development of the Bath & North East Somerset Local Flood Risk Management Strategy.

1 The Severn River Basin Management Plan is available online. 84 APPENDIX A Bath & North East Somerset Local Flood Risk Management Strategy

National Flood and Coastal Erosion • applying the Sequential Test, and if necessary the Exception Test; • safeguarding land from development that is required for current and future Risk Management Strategy flood management; The National Flood and Coastal Erosion Risk Management Strategy2 • using opportunities offered by new development to reduce the causes and was produced to ensure that government, the Environment Agency, impacts of flooding; local authorities, water companies, internal drainage boards and other • seeking opportunities to facilitate the relocation of development, including organisations that have a role in flood and coastal erosion risk management housing, to more sustainable locations where climate change is expected to understand each other’s roles. It also encourages them to work together to: increase flood risk so that existing development may not be sustainable in • understand the risks; the long-term; • manage the likelihood; • ensuring the most vulnerable new development is located in areas of lowest flood risk unless there are overriding reasons to prefer a different location, • help people to manage their own risk; and; • prevent inappropriate development, and; • ensuring development is appropriately flood resilient and resistant, including • Improve flood prediction, warning and post flood recovery. safe access and escape routes where required, and that any residual risk This Flood and Coastal Erosion Risk Management Strategy fulfils a can be safely managed, including by emergency planning, and it gives requirement in the Flood and Water Management Act (2010), which gave the priority to the use of sustainable drainage systems. Environment Agency a ‘strategic overview’ of flood and coastal erosion risk It also states local planning authorities should ensure flood risk is not management and in turn takes forward a recommendation from Sir Michael increased elsewhere and only consider development appropriate in areas Pitt’s inquiry into the 2007 floods. at risk of flooding where, informed by a site-specific flood risk assessment following the Sequential Test, and if required the Exception Test, it can be National Planning Policy Framework demonstrated that: The National Planning Policy Framework3 sets out the Government’s • the most vulnerable development is located in areas of lowest flood risk planning policies for England and was produced to help ensure sustainable unless there are overriding reasons to prefer a different location, and; development can be achieved. It provides a framework within which local • development is appropriately flood resilient and resistant, including safe people and their accountable councils can produce their own distinctive access and escape routes where required, and that any residual risk can be local and neighbourhood plans, which reflect the needs and priorities of safely managed, including by emergency planning; and it gives priority to the their communities. Within the National Planning Policy Framework it states use of sustainable drainage systems. that local plans should take account of climate change over the longer term, including factors such as flood risk by:

2 The FCERMS is available online: EA National-Strategy flooding and coastal erosion risk management summary (pdf). 3 The National Planning Policy Framework is available online. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX A 85

Plans, Assessments and Strategies Strategic Flood Risk Assessments Strategic Flood Risk Assessments are tools used by a planning authority to undertaken locally by Risk assess flood risk for spatial planning, producing development briefs, setting constraints, informing sustainability appraisals and identifying locations of Management Authorities emergency planning measures and requirements for flood risk assessments. The purpose of a Strategic Flood Risk Assessment is to assess and map Preliminary Flood Risk Assessment all forms of flood risk from groundwater, surface water, impounded water bodies, sewer and river sources, taking into account future climate change Bath & North East Somerset Council produced its Preliminary Flood Risk predictions, to allow planning authorities to use this as an evidence base to Assessment4 in 2011. The Preliminary Flood Risk Assessment provides a locate future development primarily in low flood risk areas. The outputs from a high level overview of local flooding within Bath and North East Somerset, Strategic Flood Risk Assessment also assist in the production of sustainable considering both past flooding and potential future flooding. In order to do policies for the long-term management of flood risk. this the Preliminary Flood Risk Assessment used Environment Agency Flood Risk Maps and gathered records of historic flooding. The historical flooding In 2008 the Level 1 Strategic Flood Risk Assessment was produced for information was combined into a single database using records held by the Bath & North East Somerset Council. The Strategic Flood Risk Assessment council’s land drainage and highways drainage departments, Wessex Water, provides an overview of flood risk within Bath & North East Somerset using the Environment Agency and information from Parish Councils. historical flooding records gathered from the Environment Agency and Bath & North East Somerset Council, Parish Councils, Wessex Water and local In England the Department for Environment, Food and Rural Affairs and the residents. This was supported by the use of mapping products provided Environment Agency have identified the ‘Flood Risk Areas’ on a national basis. by the Environment Agency outlining modelled flood extents and locations This has been done by identifying locations where there are clusters of 30,000 of flood defences. The Strategic Flood Risk Assessment was designed to or more people predicted to be vulnerable to surface water flooding. There are provide the information required through the planning process so that land is ten ‘Flood Risk Areas’ in England. No standalone indicative Flood Risk Areas allocated for development in low risk flood areas first. fall within the Bath and North East Somerset area. The closest Indicative Flood Risk Area to Bath and North East Somerset is that of Bristol. A relatively Following the Level 1 Strategic Flood Risk Assessment, Level 2 Strategic small portion of this area (1.5%) falls within Bath and North East Somerset Flood Risk Assessments5 were produced to focus on areas considered to be administrative boundary. Discussions with Bristol City Council have resulted at higher potential risk from flooding as a result of conclusions in the Level 1 in the agreement that they will take the lead in reviewing this indicative flood report. These Level 2 Strategic Flood Risk Assessments covered three areas: risk area on the basis that the selected location falls predominantly within their • Bath; administrative boundary. • Keynsham, and; • Midsomer Norton/ Radstock. As part of these Level 2 Strategic Flood Risk Assessments sequential tests and a scoping studies for flood risk management strategies were undertaken.

4 The Bath & North Somerset PFRA is available online 5 The level 1 & 2 SFRAs can be accessed from the Bath & North East Somerset Council website at: Evidence Base Flood Risk. 86 APPENDIX A Bath & North East Somerset Local Flood Risk Management Strategy

Flood Risk Management Strategy plans have now been incorporated into the Local Flood Risk Management Strategy, see Section 5 of the main Local Flood Risk Management Strategy Following on from the Level 2 Strategic Flood Risk Assessment a Flood Risk for further details. Management Strategy was prepared for Bath & North East Somerset. This provides strategic options for the management of flood risk in areas prioritised in the SFRA, namely, Bath, Keynsham, Midsomer Norton and Radstock. Flood Risk Management Plans This Flood Risk Management Strategy sits alongside the Council’s Local By law the Environment Agency must produce flood risk management plans Development Framework and provides guidance and advice on flood risk for each River Basin District. These must cover flooding from main rivers, the management and sustainable urban drainage systems. sea and reservoirs. Lead Local Flood Authorities that are not in Flood Risk Areas may contribute to a joint partnership Flood Risk Management Plans. Surface Water Management Plans Other Risk Management Authorities can also contribute to developing the joint partnership Flood Risk Management Plans for the River Basin District. Such Bath & North East Somerset Council has completed a regional Surface Water contributions are carried out on a voluntary basis and will result in better co- Management Plan. Surface Water Management Plans are described as a ordinated flood management. framework through which key local partners with a responsibility for surface water and drainage in their area work together to understand the causes of Lead Local Flood Authorities must also produce Flood Risk Management surface water flooding and agree the most cost effective way of managing Plans for all Flood Risk Areas covering flooding from local sources (surface that risk. The purpose is to make sustainable surface water management water, ordinary watercourses and groundwater). Bristol was identified as decisions that are evidence based, risk based, future proofed and inclusive of a Flood Risk Area as part of a Preliminary Flood Risk Assessment (which stakeholder views. A Surface Water Management Plan establishes a long- were undertaken by all Lead Local Flood Authorities). Some of the area was term action plan to manage surface water in an area and should influence identified in the Bath & North East Somerset area, but Bristol City Council future capital investment, drainage maintenance, public engagement have taken the lead on producing the Flood Risk Management Plan for this and understanding, land-use planning, emergency planning and future area. developments. The regional Surface Water Management Plan was undertaken in order to Catchment Flood Management Plans be used as an overarching framework to assist with the identification and Catchment Flood Management Plans have been produced by the management of flood risk from surface water within Bath & North East Environment Agency and are high-level planning tools that set out objectives Somerset. To understand the flood risk, data was collated and scored for flood risk management for each river catchment and estuary. They also according to its quality from Bath & North East Somerset Council records identify flood risk management policies that are economically practical, have a and those of project partners including the Environment Agency and Wessex potential life of 50 to 100 years, and will help partnership working to put them Water. Source-Pathway-Receptor modelling was then applied, and the data in place. Catchment Flood Management Plans consider inland risk from rivers, mapped to identify key flooding locations which are referred to as ‘wet spots’. surface water, groundwater and tidal flooding but do not consider sewer Based on the overall findings of the regional Surface Water Management flooding. The Bristol Avon Catchment Flood Management Plan covers Bath Plan a Strategic and Operational Action Plan was developed which identified and North East Somerset6 as three sub-areas and each has preferred policy actions which can be applied in general to address flood risk. Using the flood options identified to manage the risks most relevant to each area. history data, a location specific Action Plan was developed to summaries actions required in wet spot areas. The actions from both of these action 6 The Bath & North East Somerset Core Strategy is available online. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX A 87

In the sub-area of Bath policy option 5 is outlined as the preferred option to as may be necessary. All development will be expected to incorporate take further action to reduce flood risk. Under this it is proposed that action sustainable drainage systems to reduce surface water run-off and minimise its will be taken through carrying out improvements to existing assets below contribution to flood risks elsewhere. All development should be informed by standard; identifying an overall strategy for the future protection of the city; the information and recommendations of the Bath & North East Somerset’s increasing awareness of risk and response to flood warning developed for the Strategic Flood Risk Assessments and Flood Risk Management Strategy. area; and discouraging inappropriate development. Other policies within the Core Strategy which relate to flood risk management In the Lower Avon sub-area the preferred option is policy option 3 which include: means managing existing flood risk effectively. To do this it is proposed that a • CP2: Sustainable Construction: which states that all planning applications System Asset Management Plan be developed; investigation be undertaken should, amongst others, minimise the vulnerability to flooding and give to understand the cost efficiency of existing asset maintenance in areas such consideration of climate change adaptation. as Bathford, Swineford and Batheaston; and recommended improvements as a result of the above be implemented. • CP7: Green infrastructure: which seeks to maintain, protect and enhance green infrastructure as an integral part of creating sustainable communities. In the sub-area of Mendip Slopes and Long Ashton the preferred option is policy option 4 as it is believed that flood risk is already being managed effectively, but that further action is needed to keep pace with climate change. Strategic Environmental Assessment To implement the preferred policy option it is proposed that actions will include Under the Strategic Environmental Assessment Directive, a Strategic reviewing emergency contingency planning; increasing awareness of risk Environmental Assessment is required to accompany the Bath & North and response to flood warnings; discourage inappropriate development; and East Somerset Local Flood Risk Management Strategy. This identifies any investigate the benefits of improved flood forecasting and warnings. potentially significant environmental effects arising from the implementation of the Local Flood Risk Management Strategy so that their impact can be Core Strategy mitigated. It considered effects on water, flooding, population, human health, biodiversity, the landscape, climatic factors, material assets, cultural heritage Adopted in July 2014, the Bath & North East Somerset Core Strategy7 is one and air quality. of the main planning documents for Bath & North East Somerset Council. It sets out the Council’s vision and objectives and translates them into a deliverable plan from now up to 2029. The key policy relating to flood risk management within the Core Strategy is CP5: Flood Risk Management. This outlines Development in the District will follow a sequential approach to flood risk management, avoiding inappropriate development in areas at risk of flooding and directing development away from areas at highest risk in line with Government policy (i.e. National Planning Policy Framework). Any development in areas at risk of flooding will be expected to be made safe throughout its lifetime, by incorporating mitigation measures, which may take the form of on-site flood defence works and / or a contribution towards or a commitment to undertake such off-site measures

7 The Bath & North East Somerset Core Strategy is available online. 88 APPENDIX A Bath & North East Somerset Local Flood Risk Management Strategy

Emergency Planning Protocol To support the development of business continuity pl ans, the Council have developed an Emergency Planning Protocol8.

City of Bath World Heritage Site Management Plan The entire City of Bath is inscribed by UNESCO as a World Heritage Site and as such the UK Government and Bath and North East Somerset Council (as principal site steward) are under an international obligation to protect the outstanding heritage. This heritage may be above or below ground and flooding is identified in the City Of Bath World Heritage Site Management Plan (2010 – 2016)9 as a risk. The Local Flood Risk Management Strategy works in tandem with this plan in outlining the response to this threat. The same principle applies to the protection of archaeology and standing structures within the wider Bath and North East Somerset district.

8 The Emergency Planning Protocol can be found online: Emergency planning protocol v10 (pdf). 9 The City of Bath World Site Heritage Plan can be found online: City of Bath World Heritage Site Management Plan 2010. Appendix B Statement of stakeholder engagement 90 APPENDIX B Bath & North East Somerset Local Flood Risk Management Strategy

Contents

Introduction 91

Objectives 92

Key messages 92

Stage 1 Development of a Stakeholder Engagement Plan 93

Stage 2 Set up of the Strategic Flood Board, Operational Flood Working Group and Local Flood Reps 93

Stage 3 Stakeholder updates/briefing notes 94

Stage 4 Stakeholder Workshop 94

Stage 5 Formal Public Consultation 95 Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX B 91

Introduction

This Statement of stakeholder engagement summarises the consultation The approach has taken account of the guidance set out in the Council’s activities that have been undertaken to help shape the Bath & North East Statement of Community Involvement, the Parish Charter, and the messages Somerset’s Local Flood Risk Management Strategy. contained within the Local Government Association document ‘Framework to Assist the Development of the Local Strategy for Flood Risk Management’ It provides an overview of the 5 key stages of work: (Nov, 2011). • stage 1 – development of a stakeholder engagement plan (2014); Overall the consultation approach was based on a combination of: • stage 2 - set up of the Strategic Flood Board, Operational Flood Working • informal engagement - undertaken in parallel to the preparation of the Group and Local Flood Representatives (2014); draft Local Flood Risk Management Strategy which has helped to inform the • stage 3 – stakeholder updates/briefing notes; documents which are now out for public consultation; • stage 4 – stakeholder workshop (June 2015), and; • formal engagement – which, through the current consultation, will • stage 5 – formal public consultation (September and October 2015). invite feedback on the published draft version of the Local Flood Risk Management Strategy, and; Context • ongoing technical discussions. Bath & North East Somerset Council has a duty to undertake consultation on the Local Flood Risk Management Strategy. The Flood and Water Management Act 2010 states (in Section 9) that: “A lead local flood authority must consult the following about its local flood risk management strategy — (a) risk management authorities that may be affected by the strategy (including risk management authorities in Wales), and (b) the public.”

In preparing the draft Local Flood Risk Management Strategy the Council has undertaken engagement in order to meet, and hopefully exceed, this requirement for consultation. The Act does not specify how or when consultation should take place. The steps taken have therefore followed good practice to develop an overall engagement strategy which is embedded within and clearly influences the Local Flood Risk Management Strategy development process. 92 APPENDIX B Bath & North East Somerset Local Flood Risk Management Strategy

Objectives Key messages

Engagement on the Local Flood Risk Management Strategy aimed to help: There are a number of key messages that the stakeholder engagement and communication work undertaken has aimed to clearly and consistently • improve understanding of current and future local flood risk across Bath & convey, including the following. North East Somerset; • Bath & North East Somerset Council, as Lead Local Flood Authority, now • improve understanding of who is responsible for dealing with different types has a responsibility to work with local partners to better manage local of flooding; flooding. • encourage individuals and communities to understand their own • The Council’s responsibility, and the focus of the Local Flood Risk responsibilities and be more aware of the range of actions that they can take Management Strategy, is on the management of local flooding. This includes themselves to address flooding; flooding from surface runoff, groundwater and ordinary watercourses (small • manage expectations (in terms of what can be done to address flood risk); streams and rivers). The council will continue to work with the Environment • create positive engagement, through which a wide range of ideas about Agency, who remain responsible for flooding from main rivers. flooding can be understood and fed into the strategy; • It is not economically, technically, socially or environmentally feasible • share data and ensure that the data used to underpin the Local Flood Risk to wholly prevent flooding. However, we can reduce and mitigate the Management Strategy is as accurate as possible - ensuring that best use is impacts of flooding through good planning and management and effective made of local knowledge; investment. • maintain close liaison with flood risk management partners and pave the • Local communities have a key role to play and will themselves need to take way for a smooth working relationship with them going forward; action to help mitigate and manage local flood risk. • build awareness and positive support for the way in which the Council intend to manage local flooding going forward, and; • ensure ultimately that the final Local Flood Risk Management Strategy can be readily supported and adopted by the Council’s Cabinet. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX B 93

Stage 1 Stage 2 Development of a stakeholder engagement plan Set up of the Strategic Flood Board, Operational Flood Working Group and Local Flood Reps At the start of the project, a stakeholder engagement plan was drawn up. This identified who would need to be consulted, how and when. At an early stage in the development of the Local Flood Risk Management Strategy the Council set up an overarching process of governance to apply to The stakeholder engagement plan recognised that successful delivery of the all of its duties as Lead Local Flood Authority. Local Flood Risk Management Strategy would require close working with a range of internal partners in various departments across the Council as well as A Strategic Flood Board was set up. This includes representatives from the with a number of key external partners. It also set out a consultation timeline, Council, as well as the Environment Agency, Wessex Water, Bristol Water and which was then evolved as the project progressed. The key activities mapped the Canals and Rivers Trust. In addition, an Operational Flood Working Group out in the timeline were: has been set up. Going forwards this will discuss specific flooding or drainage issues with a view to coming up with practical measures to improve drainage • internal meetings with representatives from other Bath & North East or reduce flood risk. Both the Strategic Flood Board and the Operational Somerset Council departments; Working Group have been involved in developing the Local Flood Risk • preparation of regular update sheets/newsletters which were distributed to Management Strategy from an early stage. stakeholders; A network of Local Flood Representatives based in many of the Parishes • a stakeholder workshop; has also been set up to act as an intermediary between the Council and the • a formal consultation, supported by publicity; community and will feed information directly to the Operational Flood Working Group. • iterative feedback, with the Local Flood Risk Management Strategy documents being updated to take account of comments raised, and; • involvement of the Council’s overview and scrutiny panel. 94 APPENDIX B Bath & North East Somerset Local Flood Risk Management Strategy

Stage 3 • residents associations; • Town and Parish Councils; Stakeholder updates/briefing notes • Chamber/s of Commerce; At key stages throughout the project update sheets were prepared and • Network Rail; circulated to key stakeholders. These gave information about the emerging objectives and the tasks undertaken and were also used to advertise the • local bus and train operating companies; consultation. • cycling groups (including Sustrans and Cycle Bath); • river and flooding groups (including the Broadmead Lane Industrial Estate, Kennet and Avon Canal & River Trust, Chew Valley Flood Forum, River Stage 4 Corridor Group); Stakeholder workshop • wildlife and nature groups (including the Avon Wildlife Trust, Forest of Avon Trust, West of England Nature Partnership and RSPB); The key phase of consultation focused around a stakeholder workshop. This was held on 17th June 2015. A wide range of stakeholders were invited to • heritage groups (including Bath Preservation trust and Bath Heritage attend including: Watchdog); • members of the Strategic Flood Board, Cabinet Members and Local Ward • land owners, and; Councillors; • the Met office. • representatives from Bath & North East Somerset Council as planning The session was attended by over 30 stakeholders from a wide cross section authority and highways authority and in relation to building control, of backgrounds and disciplines. emergency planning; • Canal and River Trust; The workshop comprised of a: • English Heritage; • briefing on the role of the Council as LLFA, the background and context for the Local Flood Risk Management Strategy and the Local Flood Risk • Environment Agency; Management Strategy objectives; • Natural England; • more detailed presentation on the results of the Surface Water Management • Wessex Water; Plan (SWMP) and how these have been fed into the Local Flood Risk • Emergency Services (including Ambulance Civil Contingencies Unit, Avon Management Strategy as well as on the Local Flood Risk Management Fire and Rescue and Avon and Somerset Constabulary); Strategy Action Plan, and; • neighboring authorities (Bristol, Wiltshire, North Somerset and South • break out session which gave attendees the opportunity to discuss the Gloucestershire); Local Flood Risk Management Strategy objectives and Action Plan in more detail. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX B 95

A detailed summary of the workshop was produced and is available, on Action taken – the Local Flood Risk Management Strategy now includes request, as a separate document. This documents all the comments and a section on who to report flooding to, and links to Environment Agency queries raised and shows how each has been responded to. guidance (on the Gov.uk website) about preparing for a flood and what to do during a flood event. As a result of the workshop a number of changes were made to the emerging draft Local Flood Risk Management Strategy documents. The version that • Stakeholders felt that maintenance and clearance works to culverts and is currently out for consultation therefore incorporates these amendments. A watercourses should be prioritized. summary of these amendments is presented below: Action taken – an action has been added. • The key feeling at the workshop was that raising awareness of flooding and of responsibilities for flooding was critical and that the Local Flood Risk • Stakeholders felt that the wording of an action ‘Support communities to Management Strategy should address this. The stakeholders felt strongly manage their flood risks was misleading’ that encouraging individuals, communities and businesses to be aware of Action taken – this action has been rephrased for clarity. and manage their own flood risks was paramount, and that providing the right people with the right tools was key to doing this. • Stakeholders felt strongly that communities should be empowered to take Action taken – The Local Flood Risk Management Strategy documents control of local issues. were amended to give greater emphasis to these issues. Action taken – action added.

• Stakeholders also expressed an opinion that the Local Flood Risk Management Strategy should reflect the stages of a flood – i.e. manage, plan, warn/respond. Stage 5 Action taken – a diagram was added to show how the Local Flood Risk Formal public consultation Management Strategy objectives relate to the various stages of a flood. The public consultation period held between September and October 2015 • Stakeholders were keen to ensure that the Local Flood Risk Management formed the 5th stage of engagement. The Local Flood Risk Management Strategy took account of natural springs that can appear after heavy rain. Strategy was made available online and in libraries and one-stop-shops. A Action taken – reference to this was added to the draft Local Flood Risk questionnaire was available on line, or via hard copy, to capture comments. Management Strategy by outlining that flooding from natural springs would The Consultation was publicised in the Council’s ‘Connect’ magazine that is be considered as groundwater flooding. sent to every household in the area and was picked up in the local media. The feedback from the consultation was reviewed and analysed. Discussion was • Stakeholders were keen to ensure that the Council continues to work in then held on how appropriate comments would be used to help shape the partnership with neighbouring authorities and that information should be final version of the Local Flood Risk Management Strategy. freely shared between and within organisations. The responses to each comment and the changes as a result are available in Action taken – actions about partnership working and sharing information a ‘What’s Changed’ summary document available online. have been added.

• The stakeholders felt that, at present, it is difficult to advise the public correctly about the actions to take when a flood occurs. 96 APPENDIX B Bath & North East Somerset Local Flood Risk Management Strategy

Appendix C Roles and responsibilities of Risk Management Authorities 98 APPENDIX C Bath & North East Somerset Local Flood Risk Management Strategy

Contents

Introduction 99

Powers and duties of Risk Management Authorities 99 Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX C 99

Introduction

The Risk Management Authorities identified under the Flood and Water Risk Management Authorities. These include the Strategic Flood Board Management Act 2010 (section 6, part 13) are: and Operational Flood Working Group, which hold regular meetings. The Strategic Flood Board provides oversight and partnership working for flood • a Lead Local Flood Authority; risk management in Bath and North East Somerset. The purpose of the • the Environment Agency; Operational Flood Working Group is to discuss and agree ways to manage • a district council for an area for which there is no unitary authority; flood risk from local sources. • an internal drainage board; The Lead Local Flood Authority also attend meetings with the South West Flood Risk Managers and West of England Flood Risk Working Groups which • a water and sewerage company, and; aids communication with other Lead Local Flood Authorities in the South • a highway authority. West of England. These organisations have a duty under the Flood and Water Management Act to act consistently with (or in the case of a water company to have regard to) the Local Flood Risk Management Strategy. They are required to co-operate Powers and duties of Risk with each other and share information in the exercise of their flood and coastal erosion risk management functions. They are also able to delegate flood and Management Authorities coastal erosion functions to each other by mutual consent (except for the Table C-1 provides an overview of the powers and duties of each Risk Local Flood Risk Management Strategy which Bath & North East Somerset Management Authority, with respect to flood risk management. cannot delegate). In the case of Bath & North East Somerset the Risk Management Authorities are: • Bath & North East Somerset, as the Lead Local Flood Authority, Local Highways Authority, Local Planning Authority, and Emergency Planning Authority; • the Environment Agency; • Wessex Water; • Bristol Water (noting that burst water mains are excluded from flooding in the Flood and Water Management Act), and; • Highways England. The Lead Local Flood Authority have established a number of working groups which enable partnership working with other organisations and 100 APPENDIX C Bath & North East Somerset Local Flood Risk Management Strategy

Table C-1 Roles, duties powers and responsibilities of Risk Management Authorities Risk Management Authority Overview of role Duties, powers and responsibilities

Bath & North East Somerset Lead Local Flood Duties: Council , as Lead Local Flood Authority, responsible • develop, maintain, apply and monitor a Local Flood Risk Management Strategy, which is Authority for managing and consistent the national flood and coastal erosion management strategy; coordinating local flood • act consistently with the Local Flood Risk Management Strategy and national flood and coastal risk management; erosion management strategy; • upon becoming aware of a flood, the Lead Local Flood Authority must, to the extent is considers necessary or appropriate, investigate which authority has flood risk management responsibilities and whether that authority has or is proposing to exercise those function; • co-operate with risk management authorities for the purposes of managing flood or coastal erosion risk; • maintain a register of structures or features which are considered to significantly affect flood risk; • responsible for consenting third party works on ordinary watercourses; • statutory consultee for surface water drainage proposals for major1 planning applications, and; • contribute towards achievement of sustainable development;

Powers: • to do works to manage flood risks from surface runoff and groundwater; • designate structures and features that affect flooding; • request information from any person with respect to flood and coastal erosion; • sanction persons who do not provide information following a request for information; • enforcement where works have been completed without a necessary consent for all districts/ boroughs, and; • enforcement to maintain a proper flow on ordinary watercourses.

Other: • management and co-ordination of local flood risk, bringing together all relevant bodies to help manage local flood risk

1 Major development is defined as: a) Winning and working of mineral or the use of land for mineral working deposits, b) Waste development, c) The provision of dwellings where: i. The number of dwellings is 10 or more, ii. The site has an area of 0.5 hectares or greater, d) The provision of a building or buildings where the floor space to be created by the development is 1,000 square meters or more, or, e) A development carried out on a site having an area of 1 hectare of more. This is as defined in Article 2(1) of the Town and Country Planning (Development Management Procedure) (England) Order 2010. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX C 101

Table C-1 Roles, duties powers and responsibilities of Risk Management Authorities Risk Management Authority Overview of role Duties, powers and responsibilities

Bath & North East Somerset Responsible for Duties: Council, as the Local Highways highway drainage and • responsible for the provision and management of highway drainage and roadside ditches under Authority2 roadside ditches the Highways Act (1980). This excludes the roads that are the responsibility of the Highways Agency;

• contribute towards achievement of sustainable development, and; • statutory consultee where a development proposal is likely to affect a local highway.

Bath & North East Somerset Responsible for plan Duties: Council, as the Local Planning making and decision • preparing a Local Plan for development; Authority3 taking for new • considering flood risk assessments submitted in support of applications, and; development • determination of planning applications, giving consideration for flood risk within the region. Other: • working closely with the Drainage and Flooding team (who undertake most of the duties of the Lead Local Flood Authority) to ensure that planning applications take adequate account of drainage requirements.

Bath & North East Somerset Prepare for, Duties: Council, as the Emergency and respond to • assess the risk of emergencies occurring and use this to inform contingency planning; Planning Authority emergencies, including • put in place emergency plans; flooding • put in place business continuity management arrangements; • put in place arrangements to make information available to the public about civil protection matters and maintain arrangements to warn, inform and advise the public in the event of an emergency; • share information with other local responders to enhance co-ordination; • co-operate with other local responders to enhance co-ordination and efficiency, and; • provide advice and assistance to businesses and voluntary organisations about business continuity management.4

2 The Highways Agency have the same roles for runoff that is collected within the Highways Agency network 3 This includes being the planning authority for minerals and waste 4 Information available online: Preparation and planning for emergencies responsibilities of responder agencies and others 102 APPENDIX C Bath & North East Somerset Local Flood Risk Management Strategy

Table C-1 Roles, duties powers and responsibilities of Risk Management Authorities Risk Management Authority Overview of role Duties, powers and responsibilities

The Environment Agency Strategic overview of Duties: all sources of flood • develop, maintain, apply and monitor a strategy for flood and coastal erosion risk management in risk, and operational England; responsibility for • specific consultation body on the preparation of local plans; flooding from Main • statutory consultee for proposed developments in flood zones 2 and 3, and in areas with critical Rivers, the Sea and drainage problems in flood zone 1 where the Environment Agency has notified the local planning authority; Reservoirs • statutory consultee responsible for consenting for work or operation conducted in, over or under the bed of, or within 8 meters of the top of a bank of a Main River. • establish Regional Flood and Coastal Committees; • co-operate with risk management authorities for the purposes of managing flood or coastal erosion risk; • contribute towards achievement of sustainable development; • must report to the Minister about flood and coastal erosion risk management, and; • duty to be subject to scrutiny from Lead Local Flood Authority with respect to flood risk management functions. Powers: • designate structures and features that affect flooding; • request information from any person with respect to flood and coastal erosion; • sanction persons who do not provide information following a request for information; • manage flood risk from Main Rivers, the Sea and Reservoirs; • may make grants in respect of expenditure incurred or expected to be incurred in connection with flood or coastal erosion risk management in England; • may issue levies to the lead local flood authority for an area in respect of the Agency’s flood and coastal erosion risk management functions in that area, and; • arrange for a coastal erosion risk management function to be exercised on its behalf by a coast protection agency, Lead Local Flood Authority or Internal Drainage Board. Other: • provides fluvial and coastal flood warnings; • supports emergency responders when flooding occurs; • allocation of flood and coastal erosion risk management capital funding (Flood and Coastal Risk Management Grant in Aid5), and; • provides advice to local planning authorities in relation to development and flood risk.

5 Formally known as Flood Defence Grant in Aid Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX C 103

Table C-1 Roles, duties powers and responsibilities of Risk Management Authorities Risk Management Authority Overview of role Duties, powers and responsibilities

Wessex Water Responsible for Duties: draining foul water, and • responsible for effectually draining foul water, and roof and yard runoff from their area; runoff from roof and • duty to co-operate and may share information; yards • duty to be subject to scrutiny from Lead Local Flood Authority with respect to flood risk management functions; • adopt private sewers; • non-statutory consultee where a drainage proposal would interact with a public sewer, and; • need to have regard to the Local Flood Risk Management Strategy and the National Flood and Coastal Erosion Management Strategy.

Bristol Water Manage service Duties6: reservoirs for which • responsible for managing service reservoirs under their ownership; they are responsible • prepare on-site emergency plans for service reservoirs under their ownership; • duty to co-operate and may share information; • duty to be subject to scrutiny from Lead Local Flood Authority with respect to flood risk management functions, and; • need to have regard to the Local Flood Risk Management Strategy and the National Flood and Coastal Erosion Management Strategy.

6 Excluded burst water main flooding as this is not defined as a ‘flood’ in the Flood and Water Management Act (2010) 104 APPENDIX C Bath & North East Somerset Local Flood Risk Management Strategy Appendix D Location-specific action plan 106 APPENDIX D Bath & North East Somerset Local Flood Risk Management Strategy

Contents

Introduction 107

Action Plan 109 Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX D 107

Introduction

The regional Surface Water Management Plan is the most comprehensive A significant number of the wet-spots (42) identified in the Surface Water source of information about location-specific actions. It contains at least Management Plan had common actions around improvements to highway one action for each of the wet-spots identified as being vulnerable based and/or land drainage, and have been grouped together in the Surface Water on relevant and recent flood incident records which were analysed and Management Plan and Local Flood Risk Management Strategy. For these wet- rationalised for the period of 2009 to 2014. Historical flooding incidents spots a five stage implementation plan was identified in the regional Surface (i.e. those that occurred before 2009) have not been included to prevent Water Management Plan: misrepresentation of recorded flood incidents which may now have had • monitor; appropriate action taken. • check cyclic maintenance has been carried out; For the Local Flood Risk Management Strategy the location-specific action plan has been transposed from the Surface Water Management Plan because • investigate performance of highway/land drainage system, identifying any it is based on the most comprehensive and robust information available. maintenance or design requirements; This location-specific action plan recommends measures to investigate, • carry out required maintenance or design and construct engineering reduce or mitigate flood risk in Bath & North East Somerset, and developed scheme, and; so it can be delivered in a phased approach based on consideration of • implement continued maintenance programme. the frequency of flooding and vulnerability of receptors. In many locations the action plan recommends further investigation or survey in the first instance. This is necessary to fully understand flooding mechanisms and impacts prior to the development of flood mitigation schemes. This is a ‘live’ action plan which will be updated as measures are implemented or new information becomes available following further inspections or investigations. Its implementation will now form part of the Local Flood Risk Management Strategy as this is the overarching strategy for managing local flood risk in the region, and will be reviewed on an annual basis during preparation of the annual action plan. 108 APPENDIX D Bath & North East Somerset Local Flood Risk Management Strategy

In addition, a further 15 wet-spots identified in the regional Surface Water The action plans are set out in subsequent tables. The column headings are Management Plan have been assigned specific actions. In these wet-spots listed below for reference: the actions are bespoke to each area, and range from inspection and • Wet-spot ID: to allow cross reference with the Interactive Flood History investigation, through to scheme design and build. The following wet-spots Maps; have specific actions identified in the regional Surface Water Management Plan, and have been adopted for the Local Flood Risk Management Strategy: • Location: providing location context; • Bath City Centre; • Driver: providing justification of the action; • Batheaston and Bathford; • Action: an outline of the mitigation measure required; • Chew Magna; • Implementation Plan: step by step plan of tasks required to complete the action, split into numbered phases (1-4); • Chew Stoke; • Plan Progress at April 2015: The step on the implementation plan that each • Clandown; action is at, at the time of publication of this report. This column will be • West Harptree; updated by Bath & North East Somerset as actions progress; • Whitchurch; • Action Owner: sets out which partner or stakeholder is responsible for implementing the actions; • Keynsham; • Action Supporter: sets out which partner or stakeholder will support the • Lower Bristol Road; implementation of the action; • Timsbury; • Priority*: sets out what order the actions should be undertaken. • Midsomer Norton; • Weston and Upper Weston; • Weston Village; • Weston Park, and; • White Cross Farm (Bristol Road). Across these wet-spots 21 specific actions have been identified. 17 of these actions are considered high priority in the regional Surface Water Management Plan, with a further four considered as medium priority.

* In the context of Priority, actions have been prioritised by considering frequency of flooding and vulnerability of receptors. There are four classifications of action priority: High: indicating a recent flood events with a high frequency, affecting a more vulnerable receptor; Medium: indicating high frequency flooding affecting less vulnerable receptors OR lower frequency flooding affecting more vulnerable receptors; Low: indicating one off flood events affecting low vulnerability receptors; Complete: indicating completed actions which have been added to include where work has already been undertaken, to avoid duplicating efforts and track progress. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX D 109

Location Specific Action Plan

Wetspot ID: DA02A Driver Plan Progress at April 2015: 1 Chew Magna suffers from significant flood risk. The local flood risk Location: Chew Magna Action Owner: Lead Local Flood mechanisms are integrated with main river flooding. Investment has been made Authority in PLP measures to reduce the damage caused by flooding in this area. Action Supporter: Local Highway Action Authority Maintenance of drainage assets to enable effective drainage and source control. Priority: High Implementation Plan 1. Asset inspection 2. Undertake necessary maintenance 3. Implement a continued asset maintenance programme 4. Implement source control measures to reduce surface water runoff

Wetspot ID: DA02A Driver Plan Progress at April 2015: 1 Chew Magna suffers from significant flood risk. The local flood risk Location: Chew Magna Action Owner: Lead Local Flood mechanisms are integrated with main river flooding. The Environment Agency Authority has carried out extensive fluvial flood modelling for the catchment. Action Supporter: Environment Action Agency, Wessex Water, North Monitor and record flood incidents and continue sharing of information between Somerset Council B&NES and the Environment Agency Priority: High Implementation Plan 1. Monitor and record flood incidents Driver Plan Progress at April 2015: 2 Properties on Wallycourt Road have experienced flooding from pluvial runoff. Wetspot ID: DA02D Action Owner: Lead Local Flood Action Authority Location: Chew Stoke Engineering scheme to improve capacity and conveyance route. Action Supporter: Local Highway Implementation Plan Authority, Environment Agency 1. Implement drainage scheme Priority: High 2. Add upgraded highway gullies to Special Attention maintenance list 110 APPENDIX D Bath & North East Somerset Local Flood Risk Management Strategy

Location Specific Action Plan

Wetspot ID: DA02D Driver Plan Progress at April 2015: 1 Bilbie Close has experienced flooding from pluvial runoff. Curo (housing Location: Chew Stoke Action Owner: Curo association managing properties) has made investment in Property Level Protection measures to reduce the damage caused by flooding in this area. Action Supporter: Lead Local Flood Authority Action Property Level Protection to be installed Priority: High Implementation Plan 1. Curo (housing association) to install Property Level Protection for residents

Wetspot ID: DA03C Driver Plan Progress at April 2015: 1 West Harptree has experienced flooding as a result of blocked highway gullies. Location: West Harptree Action Owner: Lead Local Flood Action Authority Maintenance of drainage assets to enable effective drainage. Action Supporter: Local Highway Implementation Plan Authority 1. Asset inspection: is the gulley or pipework blocked Priority: High 2. Undertake necessary maintenance 3. Implement a continued asset maintenance programme

Wetspot ID: DA03C Driver Plan Progress at April 2015: 2 West Harptree has experienced flooding as a result of surcharging surface Location: West Harptree Action Owner: Lead Local Flood water sewers and gullies. Authority Action Action Supporter: Local Highway Undertake scheme to improve capacity and conveyance of drainage system. Authority Implementation Plan Priority: High 1. Engage community on potential scheme(s). 2. Implement drainage scheme. 3. Monitor performance of new systems. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX D 111

Location Specific Action Plan

Wetspot ID: DA03C Driver Plan Progress at April 2015: 2 West Harptree has experienced flooding as a result of surcharging culverted Location: Ridge Lane and Cowleaze Action Owner: Lead Local Flood Lane, West Harptree watercourses and highway drains. Authority Action Action Supporter: Local Flood Reps, Undertake scheme to improve capacity and conveyance of drainage system. Wessex Water Implementation Plan Priority: High 1. Engage community and inform how they can contribute to managing flood risk. 2. Source control measures are required to Ridge Lane and Cowleaze Lane

Wetspot ID: DA05A Driver Plan Progress at April 2015: 1 Development is planned on the fringe of Whitchcurch. Location: Whitchurch Action Owner: Wessex Water, Action Developer Upgrade Surface Water sewer system for the area. Action Supporter: Lead Local Flood Implementation Plan Authority, Local Planning Authority 1. Design a drainage scheme which will work within the current restrictions Priority: High

Wetspot ID: DA05A Driver Plan Progress at April 2015: 1 This area is defined as a Flood Risk Area and Bristol Lead Local Flood Authority Location: Whitchurch Action Owner: Lead Local Flood is taking the lead on the Flood Risk Management Plan Authority Action Action Supporter: Bristol City Lead Any proposed developments must consider the Flood Risk Management Plan Local Flood Authority, Local Planning for the area. Authority Implementation Plan 1. Inform developers of the Flood Risk status 112 APPENDIX D Bath & North East Somerset Local Flood Risk Management Strategy

Location Specific Action Plan

Wetspot ID: DA08B Driver Plan Progress at April 2015: 2 East Keynsham (A4) has experienced flooding from a number of sources Location: Keynsham Action Owner: Lead Local Flood including fluvial interactions, pluvial runoff and highway gulley blockage. Authority Action Action Supporter: Local Highway Monitor future flood incidents in this area, if flooding continues to cause Authority, Environment Agency, Wessex disruption, upgrade works to highway drainage may be required. Water Implementation Plan Priority: High 1. Monitor flooding at this location 2. Understand the cause of flooding 3. Assess the need for upgrade works to the drainage network

Wetspot ID: DA10B Driver Plan Progress at April 2015: 1 Bloomfield Road has experienced surface water flooding, particularly as a result Location: Timsbury Action Owner: Local Highway of blocked highway gullies. Authority Action Action Supporter: - Maintenance of drainage assets to enable effective drainage. Priority: High Implementation Plan 1. Asset inspection: is the gulley or pipework blocked 2. Undertake necessary maintenance 3. Implement a continued asset maintenance programme

Wetspot ID: DA11A Driver Plan Progress at April 2015: 1 Midsomer Norton has experienced flooding from a number of sources across Location: Midsomer Norton Action Owner: Lead Local Flood the town. Authority Action Action Supporter: Local Highway Work with Environment Agency to better understand hydraulics and flood risk. Authority, Environment Agency, Wessex Implementation Plan Water 1. Undertake integrated hydraulic modelling Priority: High Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX D 113

Location Specific Action Plan

Wetspot ID: DA16A Driver Plan Progress at April 2015: 1 Significant areas of development are planned on the fringes of Upper Weston Location: Weston and Upper Action Owner: Lead Local Flood Weston and Weston. Authority, Developer Action Action Supporter: - Manage the risk of exacerbating an existing surface water problem by considering drainage at master planning stage. Priority: High Implementation Plan 1. Establish the current status of the planning applications 2. Inform the developer of the wet-spot status 3. Design a drainage scheme which will work within the current restrictions

Driver Plan Progress at April 2015: 1&2 This is a steep catchment. There is a potential flood risk stemming from Wetspot ID: DA16A Action Owner: Lead Local Flood maintenance of a culverted watercourse through the village. Authority Location: Weston Village Action Action Supporter: Wessex Water, Undertake study of flooding issues and identify potential measures. Environment Agency Implementation Plan 1. Engage local community 2. Commission study 3. Identify potential improvements 4. Identify funding opportunities

Wetspot ID: DA16D Driver Plan Progress at April 2015: 3 Weston Road has experienced flooding. The sources have not been well Location: Weston Park Action Owner: Lead Local Flood documented but includes highway gulley blockage. Authority Action Action Supporter: - Maintenance of drainage assets to enable effective drainage. Priority: High Implementation Plan 1. Asset inspection: is the gulley or pipework blocked 2. Undertake necessary maintenance 3. Implement a continued asset maintenance programme 114 APPENDIX D Bath & North East Somerset Local Flood Risk Management Strategy

Location Specific Action Plan

Wetspot ID: DA16G Driver 3. Assess the need for upgrade Bath City Centre has experienced flooding. The quality of data recorded has works to the drainage network Location: Bath City Centre however not always provided enough information to properly understand the Plan Progress at April 2015: 1 mechanism for why flooding has occurred. Likely sources include fluvial, surface water / pluvial, groundwater and highway gulley blockage. Action Owner: Lead Local Flood Authority Action Action Supporter: Lead Local Flood Continue to monitor flood incidents in this area, if flooding continues to cause Authority, Local Highway Authority, disruption, upgrade works to highway drainage may be required. Environment Agency, Wessex Water Implementation Plan 1. Monitor flooding at this location 2. Understand the cause of flooding

Priority: High Driver Plan Progress at April 2015: 1 Surface water flooding and highway drainage issues known. Significant Wetspot ID: DA16G Action Owner: B&NES Major projects development and associated river Avon flood risk improvements planned. Location: Lower Bristol Road Action Supporter: Environment Action Agency, Lead Local Flood Authority Ensure any development/ flood risk scheme appreciates surface water flood risk. Implementation Plan 1. Ensure developer is aware of surface water flooding issues (and potential interaction with river Avon). Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX D 115

Location Specific Action Plan

Wetspot ID: DA02B Driver Plan Progress at April 2015: 1 Winford Road has experienced flooding as a result of pluvial runoff and Location: Chew Magna, Winford Action Owner: Local Highway Road and Littleton Lane blockage on a highway structure. Investment has been made in PLP measures Authority to reduce the damage caused by flooding in this area. Action Supporter: Lead Local Flood Action Authority The highway drainage assets require maintenance and an assessment of capacity. Priority: Medium Implementation Plan 1. Asset inspection: is the culvert blocked 2. Maintenance of culvert 3. Monitor future flooding incidents at this location 4. Assess the need for upgrade works to the drainage network

Wetspot ID: DA02C Driver Plan Progress at April 2015: 1 Chew Stoke has experienced surface water flooding, particularly from pluvial Location: Chew Stoke Action Owner: Bath & North East runoff. Investment has been made in PLP measures to reduce the damage Somerset Council, Wessex Water caused by flooding in this area. Action Supporter: Local Flood Action Representatives, Environment Agency Source control measures are required to mitigate the flood risk in this area. Priority: Medium Implementation Plan 1. Engage the community and inform how they can contribute to managing flood risk 2. Promote Wessex Water’s save water scheme, providing discounts of the purchase of a water butt 116 APPENDIX D Bath & North East Somerset Local Flood Risk Management Strategy

Location Specific Action Plan

Wetspot ID: DA03B Driver Plan Progress at April 2015: 1 Bristol Road has experienced flooding from blocked gullies and drainage Location: White Cross Farm Action Owner: Bath & North East ditches. Somerset Council Action Action Supporter: Local Flood Education of riparian owners on their rights and responsibility. Representatives Implementation Plan Priority: Medium 1. Engage the community and inform how they can contribute to managing flood risk 2. Explain the importance of maintenance to ditches

Wetspot ID: DA11C Driver Plan Progress at April 2015: 1 Springfield Place has experienced flooding from an ordinary watercourse. Location: Clandown Action Owner: Bath & North East Action Somerset Council Education of riparian owners on their rights and responsibilities. Action Supporter: Local Flood Implementation Plan Representatives 1. Engage the community and inform how they can contribute to managing Priority: Medium flood risk 2. Explain the importance of maintenance to ditches Appendix E Review of Funding Sources 118 APPENDIX E Bath & North East Somerset Local Flood Risk Management Strategy

Contents

Introduction 119

Tier 1 – Dedicated Flood Risk Management Funding Sources 119 Flood and Coastal Erosion Risk Management Grant in Aid 119 Local Levy 120 Lead Local Flood Authority Grant for New Responsibilities 120 One off grants 120

Tier 2 – Economic Growth and Beneficiaries funding sources 121 Local Authority Revenue Funding 121

Funding Sources Relating to Development and Regeneration 121 Section 106 Agreements 121 Community Infrastructure Levy 121 Local Enterprise Partnership Funding 122 Regional Growth Fund 122 Private Beneficiary Funding 122

Tier 3 – Non Flood Risk Management Funding Sources 123 European Union 123 Lottery 123 Land management funding sources 124 Water Framework Directive Funding 124 Non-Government Organisations and Charitable Trusts 124 Community Fundraising and Events 124 Public Appeals and Volunteering 125 Trusts 125 Landfill Communities Fund 125 Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX E 119

Introduction Tier 1 – Dedicated Flood Risk This section sets out the potential sources of funding available for flood risk Management Funding Sources management works in Bath and North East Somerset and has been split into a tiered approach as shown in Figure E-1 and described in the main Local Funding from dedicated flood risk management sources will most likely Flood Risk Management Strategy document. make up the majority of the funding mix for delivering the Bath & North East Somerset Strategy measures, supported by other alternative sources. The Figure E-1 Options for funding of capital flood risk management works. following expands on current dedicated funding sources available for flood risk management purposes.

• Flood and Coastal Erosion Risk Tier 1: Flood Risk Flood and Coastal Erosion Risk Management Grant in Aid Management Management Grant in Aid • Local Levy In relation to flood risk management, capital funding from Government is 1 • Revenue funding for Lead Local Flood provided through Flood and Coastal Erosion Risk Management Grant-in-Aid . Authority and funding for statutory consultee This is provided by the Department for Environment, Food and Rural Affairs role for surface water drainage and administered and managed by the Environment Agency, although funding • One off grants, such as repair and renew approvals are also subject to the consent of the relevant Regional Flood and grants Coastal Committee. Bath & North East Somerset Council falls within the Wessex Regional Flood and Coastal Committee and both Councilor Charles Gerrish and Councilor Brian Simmons sit on this committee. The Wessex Tier 2: Economic • Local Authority Capital & Revenue Funding Regional Flood and Coastal Committee area is shown on this Environment growth and • Development and economic growth Agency map – map avialabe online. beneficiaries sources (e.g. Local Enterprise Partnership, S.106, or Community Infrastructure Levy) Flood and Coastal Erosion Risk Management Grant-in-Aid is available to • Beneficiaries of the scheme projects relating to all sources of flooding, and has historically been the most (e.g. homeowners, businesses important source of funding for flood risk management and coastal erosion or utility providers) schemes. Flood and Coastal Erosion Risk Management Grant-in-Aid is not available to fund studies that are not materially linked to a flood risk scheme (e.g. it will fund a Project Appraisal Report which can lead to the development Tier 3: Non Flood • Third party funding (e.g. European, lottery of a scheme). Risk Managament or community fundraising) Sources However, Flood and Coastal Erosion Risk Management Grant-in-Aid is unlikely to meet the full scheme costs in most cases (as outlined for the Bath Flood Risk Management Project). For the Bath Flood Risk Management Project a Flood and Coastal Erosion Risk Management Grant-in-Aid contribution of £0.6m for 2014/15 was made towards scheme costs (with a further £0.5m from Regional Flood and Coastal Committee Local Levy. This roughly equaled 12% of the scheme cost.

1 This is formerly known as Flood Defence Grant in Aid 120 APPENDIX E Bath & North East Somerset Local Flood Risk Management Strategy

Detailed explanatory notes and a spreadsheet calculator tool are available to Burdens Assessment establishing the payment required to ensure that Lead guide practitioners through the Flood and Coastal Erosion Risk Management Local Flood Authorities will have sufficient financial resources to meet the Grant-in-Aid application process. Up to date information, including a full table expectations of their new statutory consultee role on planning applications in of the outcome measures and benefits under each that will qualify for national relation to surface water drainage for major development, The Department funding is available online: Flood and coastal defence appraisal of projects. for the Environment, Food and Rural Affairs have since provided funding to all Lead Local Flood Authorities for the first year (2015/16) of their new Local Levy statutory consultee role and for one off costs to prepare IT, internal systems, train stakeholders, raise awareness and develop advice. A small contribution Local Levy can be raised by Wessex Regional Flood and Coastal Committee to fund the burden of providing technical advice and administration is also by way of a levy precept on Bath & North East Somerset Council and other expected to be provided to Lead Local Flood Authorities for the first 3 years relevant local or unitary authorities. Local Levy funding can be used to support (up to 2017/18), but this has not yet been secured. flood risk management projects that do not attract 100% national funding through Flood and Coastal Erosion Risk Management Grant-in-Aid, thus One off grants enabling locally important projects to be undertaken to reduce the risk of flooding within the RFCC area. Funds raised using this existing Regional Flood Government occasionally makes funding available through one-off grants and and Coastal Committee local levy will count as a local contribution in terms pilot projects. Working together, Risk Management Authorities within Bath & of the Flood and Coastal Erosion Risk Management Grant-in-Aid process, North East Somerset area should bear this in mind and be prepared to identify even though the levy is supported by funding through the Department of and apply for appropriate opportunities if and when they arise. Previous Communities and Local Government. examples have included the Department for Environment, Food and Rural Affairs early action fund for surface water schemes in 2010, and the repair and Lead Local Flood Authority Grant for New Responsibilities renew grant following significant national flooding in 2013/143. In December 2010 the Department for Environment, Food and Rural Affairs announced £21million worth of grants to provide additional funding specifically to support Councils with Lead Local Flood Authority status. This was in addition to existing Formula Grant arrangements, and was aimed to allow Lead Local Flood Authorities to perform new roles and duties under the Flood and Water Management Act and Flood Risk Regulations. In 2015/16 £37,0002 was allocated to Bath & North East Somerset Council, but there is no certainty of funding from Central Government beyond 2015/16. Also, once allocated, these funds are not ring-fenced so in order to access them it is important to raise awareness of flood risk and keep it near the top of the local political agenda to ensure funding can be gained. The Communities and Local Government Department published a New

2 South West and Wessex Regional Flood and Coastal Committee map (pdf). 3 Flooding recovery households and businesses applying for the repair and renew grant scheme. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX E 121

Tier 2 – Economic Growth and Funding Sources Relating to Beneficiaries funding sources Development and Regeneration

Section 106 Agreements Local Authority Revenue Funding Section 106 agreements can be used to support the provision of services and Local authorities have additional capital and revenue budgets which can be infrastructure, including flood risk management measures. The agreements used to supplement investment in flood risk management. This is particularly provide a means to ensure that a proposed development contributes to the relevant where measures or schemes, such as Sustainable Drainage Systems, creation of a sustainable environment, particularly by securing contributions can be identified which create multiple benefits across a number of Bath & towards the provision of infrastructure and facilities. Between 2003 and 2013 North East Somerset Council’s duties such as highways and public open £24.4m was collected in the Bath & North East Somerset area through this space. method. Whilst only small amounts of this funding are directly attributable to However, in the current economic times, there are budgetary constraints use on flood management works, flood management and site viability is key across Bath & North East Somerset Council area. This was highlighted in to a developer’s willingness to contribute to this type of agreement which has the Bath & North East Somerset Community Infrastructure Levy Funding wider implications for development and improvements to the area. The earlier Gap Evidence Paper4 where it was identified that there is a total £234 million any local flood risk management costs associated with a site are identified the funding gap in order to deliver key and desirable infrastructure to support better as developers can then factor these costs into the price of the land and planned Core Strategy growth. This includes an estimated £6.8 million gap for make better informed decisions as to the overall viability of the site. the ongoing support of water and drainage infrastructure. The two primary sources of income for Bath & North East Somerset are: Community Infrastructure Levy • council tax collected from local residents, and; The Community Infrastructure Levy is a ‘tariff’ style charge, which allows local authorities to charge developers to contribute to the cost of providing some of • settlement Funding Assessments which replaced Formula Grants. Each the infrastructure needed to support the development of the area where there local authority’s Settlement Funding Assessment is comprised of Revenue is a demonstrable need and once this need has gone through a process of Support Grant and Baseline Funding Levels, which is their share of the local examination. share of business rates5. Bath & North East Somerset Council is consulting on the charging schedule for the implementation of a Community Infrastructure Levy as it has been identified that there is a funding gap to deliver Core Strategy growth for the area. Following the planned implementation of Community Infrastructure Levy in the Bath & North East Somerset area, Planning Obligations or Section 106 contributions will be replaced for many forms of infrastructure. However, Section 106 agreements will still be used for site-specific mitigation measures

4 CIL Evidence Background Paper (pdf). 5 Breakdown of settlement funding assessment final local government finance settlement to 2016. 122 APPENDIX E Bath & North East Somerset Local Flood Risk Management Strategy and for affordable housing provision. are the main priorities of this fund. This could potentially mean that if projects are correctly developed and targeted there could be funding available from this Key to obtaining funding towards flood risk schemes from this source will source to support flood risk projects. However, as yet this has not been tested. be proactive infrastructure planning through the Infrastructure Delivery Plan process. This will provide a high level summary of anticipated major infrastructure funding requirements that the Council will be seeking to fund Regional Growth Fund partially or fully through Community Infrastructure Levy. Schemes which The Regional Growth Fund is a £3.2 billion fund operating across England are included in the Infrastructure Delivery Plan will be more likely to obtain from 2011 to 2017, and aims to support eligible projects and programmes Community Infrastructure Levy contributions. that are also raising private sector investment to create economic growth and sustainable employment. This funding source is unlikely to offer a realistic Local Enterprise Partnership Funding source of funding for local flood risk management schemes unless there are clear benefits to private business such as expansion and job growth through Local Enterprise Partnerships have been set up to provide strategic leadership greater productivity or more available land. and set out local economic properties to help support the Government’s Local Growth White Paper. The West of England (Local Enterprise) Partnership covers the Bath & North East Somerset area. Private Beneficiary Funding The roles of the Local Enterprise Partnership set out in the White Paper relating Funding can be levied from private sector beneficiaries of a flood risk to funding include: management scheme in a number of ways, which are outlined below. • working with Government to set out key investment priorities; • Business rate supplement: Bath & North East Somerset Council has the power to levy a local Business Rate Supplement and to retain the proceeds • coordinating approaches to leveraging funding from the private sector, and; for investment in that area. Proceeds must be spent on projects which • coordinating proposals or bidding directly for the Regional Growth Fund contribute to the economic development of the local area. (expanded in section 2.4 of the White Paper). • Business Improvement Districts: this is a defined area within which In 2012 £11,579,541 was allocated to the West of England Partnership businesses pay an additional tax or fee in order to fund improvements within through the Growing Places Fund to tackle immediate infrastructure investment the council’s boundaries. Flood risk management schemes could potentially constraints. The main aim of this fund is to focus on housing and transport, but access funding from this source if they could be demonstrated to provide if for example solutions to reduce flood risk for homes are proposed these may specific benefits to businesses within the area. be eligible. • Direct Beneficiary Contributions: There are currently limited case study From 2014 Local Enterprise Partnerships have been given responsibility for examples of beneficiary contributions from companies or corporate bodies. delivering part of the European Union Structural and Investment Fund, and the However, one such example is the Sandwich tidal flood defence scheme, West of England Partnership has been allocated €68.6m to spend between where a private company provided significant funding towards the scheme . 2014 and 2020. Guidance published in 2013 suggests that activities to • Utility providers may be willing to contribute towards a flood risk management support; innovation, research and technologic development; small businesses; scheme, if the applicant can demonstrate the long term benefits of flooding employment; skills; social inclusion; or development of a low carbon economy on their customer supply.

6 More information is available at online at the Environment Agency website. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX E 123

In addition, some corporate bodies may be persuaded to contribute to flood risk management measures. There are a number of ways to approach Tier 3 – Non Flood Risk Management corporate giving. However, for every penny that they provide they need to see a clear commercial benefit be it in terms of marketing, promotion, training, or Funding Sources reduction in flood risk. European Union • Employee Volunteering: Brings in very little financial support but can provide good PR and will boost volunteer numbers. European Union funding is a complex and specialist field. Some authorities have invested proactively in this area of fundraising and are experienced in • Sponsorship: Generally provides low level support, averaging around a few obtaining funds through this route; for example Cornwall and the Isles of thousand pounds. It is normally used to raise the profile of the company in Scilly prepared a detailed evidence base to bid for Convergence status in the local community so needs to be high profile. 2005 and thereby gained access to funding through this European economic regeneration programme. Funding from the European Union generally needs to be for projects which are innovative. Applicants need to be in a partnership that includes at least four other projects spread across the European Union and they need to demonstrate the transference of learning across the areas. Grants tend to be in the region of a few million pounds spread across all participants. The administrative burden on the main applicant can be considerable and needs to be considered when budgeting for European Union fundraising. Relevant funding sources to be investigated include the following: • European Regional Development Fund; • European Agricultural Fund for Rural Development, and; • European Social Fund The European Investment Bank has expressed a willingness to fund flood defence projects through loans at a competitive rate, but this is only generally provided for large scale multi million pound projects.

Lottery All the major lottery funding providers (Heritage Lottery Fund, Big Lottery, and Arts Council) have clear guidelines and funding streams. Each of these operates on slightly different timescales and has various specific requirements. Grants ranging from a few hundred to several million (depending on the type and scale of project) are awarded to sport, heritage and community activities 124 APPENDIX E Bath & North East Somerset Local Flood Risk Management Strategy and projects that make a positive contribution towards education, health and However, it should be noted that funding through the Water Framework the environment in local communities. Flood risk management projects may Directive is assessed on a case by case basis and not guaranteed. be eligible if they can demonstrate that they do this, for example by improving social cohesion through volunteering to clean up local waterways. One Non-Government Organisations and Charitable Trusts example is Awards for All, which provides grants for projects that will help to improve the lives of individuals, boost creativity or encourage more people to Many local flood risk management projects are on a fairly small, localised get involved in local communities. scale and may struggle to access, or attract funding from, sources outlined here. In these instances grants or donations from sources such as Non- Government Organisations or charities can provide an additional/alternative Land management funding sources route for funding. Countryside Stewardship is a scheme under the European Union Common A Non-Government Organisation or charitable trust could consist, for Agricultural Policy and provides incentives for land managers to look after example, of local residents with a common interest in protecting their town their environment. From 2015 it was opened to all eligible farmers, woodland against flood risk to undertake necessary works such as implementation of owners, foresters and other land managers. Sustainable Drainage System measures to reduce surface water flooding, or Under this Countryside Stewardship, water capital grants are available for ongoing maintenance of local flood defenses. farmers and land managers in priority catchments, to fund infrastructure Another route that can be utilised to drive down operation & management works to help reduce water pollution from agriculture. Through this initiative up costs is through the establishment of partnerships that take responsibility for to £10,000 per holding may be made available, but the scheme is competitive schemes after their completion. Schemes with a particular wildlife interest and applications will be scored and accepted subject to the budget available7. could for example be packaged to attract the support of the local Wildlife Applications are also only open for a limited period each year. Although this Trust or the RSPB. is targeted funding it may be a potential source of funding for local flood risk management where water quality improvement from agricultural land can also be demonstrated. Community Fundraising and Events Community fundraising means raising money via a series of volunteer Water Framework Directive Funding run events, sponsorship, and from established local groups. It is a time consuming way of raising small sums of money, but a great way to deliver If it can be demonstrated that local flood risk management projects can community engagement and ownership which can in itself help a project to contribute towards ensuring ecological status of local waterbodies can be qualify for other sources of funding. improved through measures to be implemented, then it may be possible to obtain funding from the Water Framework Directive. An example of this could The connection for participant and donor needs to be immediate, obvious be that through controlling soil erosion of land upstream in a catchment in an and usually selfless. In Cockermouth, Cumbria, the local community raised attempt to reduce local flood risk, sediment loads to a river are also controlled £215,000 towards the flood alleviation scheme, with contributions coming which would improve water quality and thus ecological status. from local residents and businesses8.

7 Further details are available online: Guide to countryside stewardship water capital grants 2015. 8 Cockermouth flood alleviation scheme funded by a partnership approach. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX E 125

Public Appeals and Volunteering Landfill Communities Fund Closely allied with community fundraising, public appeals tend to be cost If the project site is within a certain distance of a landfill site funding can be heavy, but can generate reasonable returns if aimed at the right target sought from a range of landfill operators. audience. The Landfill Communities Fund (formerly the Landfill Tax Credit Scheme) The best public appeals tap into an established community need or enables landfill site operators to claim tax credit for contributions they make awareness and can be run via the local media and the internet. A ‘friends to approved environmental bodies for spending on projects that benefit the of’ scheme is often a good way to get this type of mechanism kick-started. environment. The environmental bodies are those enrolled by Entrust, the Well run, high quality volunteering actually costs money, but by incorporating regulatory body for the scheme. Further details are available online: Landfill structured volunteering opportunities the project increases its community Community Fund. engagement and develops a sense of ownership in both the problem and solution. Volunteering can be used to bring in funding by counting as match funding. By enhancing a volunteer project with structured training funding can be obtained from back to work schemes and government initiatives to tackle the growing number of people not in education, employment or training.

Trusts There are thousands of grant making trusts across the country. Most, but not all, favour outcome led projects so this needs to be borne in mind when packaging up projects. Trusts are unlikely to fund large scale infrastructure projects, but they may want to fund a programme of education about the causes and prevention of flooding for example. Potential trusts in Bath & North East Somerset who may be willing to provide sources of funding could include the National Trust, Canals and Rivers Trust, Primary Care Trust or Bath Preservation Trust. Although not technically a trust, Bath University may also be willing to provide support in the form of research for example, but this would need to be discussed based on individual project needs. 126 APPENDIX E Bath & North East Somerset Local Flood Risk Management Strategy Appendix F Glossary 128 APPENDIX F Bath & North East Somerset Local Flood Risk Management Strategy

Aquifer Critical Infrastructure An aquifer is an underground layer of water-bearing permeable rock, rock A term used to describe the assets that are essential for the functioning of a fractures or unconsolidated materials (gravel, sand, or silt) from which society and economy. Most commonly associated with the term are facilities groundwater can be extracted using a water well. for: electricity generation, transmission and distribution; gas production, transport and distribution; oil and oil products production, transport and Catchment Flood Management Plan distribution; telecommunication; water supply (drinking water, waste water/ sewage, stemming of surface water (e.g. dikes and sluices)); agriculture, A Catchment Flood Management Plan is a high-level strategic plan through food production and distribution; heating (e.g. natural gas, fuel oil, district which the Environment Agency seeks to work with other key-decision heating); public health (hospitals, ambulances); transportation systems (fuel makers within a river catchment to identify and agree long-term policies for supply, railway network, airports, harbours, inland shipping); financial services sustainable flood risk management. (banking, clearing); and security services (police, military).

Civil Contingencies Act (2004) Dwelling Legislation that aims to deliver a single framework for civil protection in the United Kingdom and sets out the actions that need to be taken in the event of A self-contained house, flats or other places of residents. a flood Elected Members Climate Change Local councillors are elected by the Bath & North East Somerset community A long-term change in the statistical distribution of weather patterns over to decide how the council should carry out its various activities. periods of time that range from decades to millions of years. It may be a change in the average weather conditions or a change in the distribution of Flood weather events with respect to an average, for example, greater or fewer extreme weather events. Climate change may be limited to a specific region, Flooding is caused when land not normally covered by water becomes or may occur across the whole Earth. covered by water. A road or property can be flooded when: • there is exceptional rainfall, which is greater than the capacity of drainage Combined sewer systems; A sewer through which surface and foul water passes. • drainage systems are not well maintained, or there are blockages/collapses in the drainage network; Conservation of Habitats and Species Regulations (2010) • there is increased runoff from adjoining fields or hard standing areas, or An Act which transposed the Habitats Directive into United Kingdom law. • a river of watercourse overflows The regulations aim to help maintain and enhance biodiversity throughout the European Union, by conserving natural habitats, flora and fauna. The main way it does this is by establishing a coherent network of protected areas and strict protection measures for particularly rare and threatened species. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX F 129

Flood and Water Management Act (2010) Green belt The Act brings together the recommendations of the Pitt report and previous Protected areas of reserved open land, mainly around large cities, for the policies, to improve the management of water resources and create a more purpose of preventing urban sprawl by keeping land permanently open. Policy comprehensive and risk based regime for managing the risk of flooding from CP8 of our Core Strategy, adopted in 2014, details our Green Belt policy. all sources. The Act states that its purpose is to “make provision about water, including provision about the management of risks in connection with flooding Grey-water recycling and coastal erosion.” Generally defined as wastewater from bathrooms and laundries, grey- water can come from our showers, baths and washing machines. With the Flood Risk appropriator system fitted, much of this grey-water can be reused for flushing Flood risk is a combination of two components: the chance (or probability) of toilets etc. a particular flood event and the impact (or consequence) that the event would cause if it occurred Groundwater flooding Groundwater flooding occurs where the water levels in rock and soil become Fluvial high enough for the water to appear near to or above the ground surface. This The processes associated with rivers and streams and the deposits and may happen, for example, where there are underlying gravels, or porous or landforms created by them fractured rocks, allowing water to pass through.

Flood Risk Regulations (2009) Lead Local Flood Authority Transposes the European Commission Floods Directive (Directive 2007/60/ Lead Local Flood Authorities are county councils and unitary authorities. EC on the assessment and management of flood risks) into domestic law and Under the Flood and Water Management Act (2010), Lead Local Flood implements its provisions. The regulations outline the roles and responsibilities Authorities are required to: of the various authorities consistent with the Flood and Water Management • Prepare and maintain a strategy for local flood risk management in Act (2010) and provide for the delivery of the outputs required by the directive. their areas, coordinating views and activity with other local bodies and The Directive requires Member States to develop and update a series of tools communities through public consultation and scrutiny, and delivery planning. for managing all sources of flood risk. • Maintain a register of assets – these are physical features that have a significant effect on flooding in their area. Flood Zones • Investigate significant local flooding incidents and publish the results of such Nationally consistent delineation of ‘high’ and ‘medium’ flood risk. Updates investigations are published on a quarterly basis by the Environment Agency. • Consult on planning applications for major development. Foul sewer • Issue consents for altering, removing or replacing certain structures or A sewer that is designed to carry contaminated wastewater to a sewage features on Ordinary Watercourses. works for treatment. • Play a lead role in emergency planning and recovery after a flood event. 130 APPENDIX F Bath & North East Somerset Local Flood Risk Management Strategy

Local Flood Risk National Planning Policy Framework Defined in the Flood and Water Management Act (2010) as flooding from Framework which sets out the Government’s planning policies for England surface water runoff, Ordinary Watercourses and groundwater and how these are expected to be applied. It acts as guidance for local planning authorities and decision-takers, both in drawing up plans and making Local Flood Risk Management Strategy decisions about planning applications. A strategy which must be completed by a Lead Local Flood Authority and National Flood and Coastal Erosion Risk Management Strategy National must: strategy which provides the overarching framework for future action by all risk management authorities to tackle flooding and coastal erosion in England. • Assess the local flood risk. • Set out objectives for managing local flooding. Operational Flood Working Group • List the costs and benefits of measures proposed to meet these objectives, The purpose of the Operational Flood Working Group is to discuss and agree and how the measures will be paid for. ways to manage flood risk from local sources. The Operational Flood Working Group will discuss specific flooding or drainage issues with a view to coming Local Flood Representatives up with practical measures to improve drainage or reduce flood risk. The group consists of technical officers from the Drainage and Flooding team, An individual nominated by their Parish Council or Federation of Bath the Environment Agency and Wessex Water, as well as other invited Council Residents’ Associations Group to liaise with Bath & North East Somerset officers and Local Flood Representatives as required. Council’s Drainage & Flooding team. They provide an important communication link between residents in the Parish and the Council and other Flood Risk Management stakeholders on issues of land drainage, surface Ordinary Watercourse water flooding, groundwater flooding and watercourse flooding. Any section of watercourse not designated as a Main River.

Local Planning Authority Our Partners Body that is responsible for controlling planning and development through the Include: Risk Management Authorities, the West of England Local planning system. Enterprise Partnership, members of the Strategic Flood Board, Operational Flood Working Group, internal departments with Bath & North East Main River Somerset Council, Elected Members, Local Communities and Local Flood Representatives. All watercourses shown on the statutory main river maps held by the Environment Agency and the Department for Environment, Food and Rural Affairs. This can include any structure or appliance for controlling or regulating Pluvial the flow of water into, in or out of the channel. The Environment Agency has Flows that relate to or are characterised by rainfall. permissive power to carry out works of maintenance and improvement on these rivers. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX F 131

Preliminary Flood Risk Assessment Sequential Test High level screening exercise to identify areas of significant local flood risk Informed by a Strategic Flood Risk Assessment, a planning authority applies from sources including surface water, groundwater, Ordinary Watercourses the Sequential Test to demonstrate that there are no reasonably available and manmade structures such as canals or sewers but excluding of main sites in areas with less risk of flooding that would be appropriate to the type of rivers. development or land use proposed.

Rainwater harvesting Sewer flooding The harvesting of rainwater simply involves the collection of water from The consequence of sewer systems exceeding their capacity during a rainfall surfaces on which rain falls, and subsequently storing this water for later use. event.Strategic Flood Risk Assessment Normally water is collected from the roofs of buildings and stored in rainwater A Strategic Flood Risk Assessment is used as a tool by a planning authority tanks. Water butts that capture rain water from roofs that is then used to to assess flood risk for spatial planning, producing development briefs, setting water gardens is a common example of rainwater harvesting. constraints, informing sustainability appraisals and identifying locations of emergency planning measures and requirements for flood risk assessments. Return period The probability of a flood of a given magnitude occurring within any one year Statutory Consultee e.g. an event with a 1 in 100 chance of occurring has a 1% probability of An organisation who must provide a substantive response to the local occurring in any given year i.e. has a 1% annual exceedance probability. It is planning authority, within a set deadline, prior to a decision being made on a important to note that a 1 in 100 year event could occur twice or more within planning application. 100 years, or not at all.

Strategic Flood Board Riparian Owner The Strategic Flood Board provides oversight and partnership working All landowners whose property is adjoining to a body of water have the right for flood risk management in Bath & North East Somerset. It includes to make reasonable use of it and suitably maintain it. representatives from Bath & North East Somerset, the Environment Agency, Wessex Water, Canal & River Trust, Bristol Water, and Avon Fire and Rescue. Risk Management Authority Defined in the Flood and Water Management Act (2010), they all have some Sustainable Drainage Systems responsibility for managing flood risk Sustainable drainage systems are approaches that manage surface water by taking into account water quantity (flooding), water quality (pollution) and Section 19 Investigations amenity issues. Flood investigations which must be undertaken by Lead Local Flood Authorities in accordance with Section 19 of the Flood and Water Management Act (2010). 132 APPENDIX F Bath & North East Somerset Local Flood Risk Management Strategy

Surface water runoff West of England Partnership Rainwater (including snow and other precipitation) which: is on the surface of A partnership group established comprising of Bristol, Bath & North East the ground (whether or not it is moving); and has not entered a watercourse, Somerset, North Somerset, and South Gloucestershire Councils, with the draining system or public sewer. purpose of producing consistent Sustainable Drainage Systems guidance across the region. Surface Water Management Plan West of England Local Enterprise Partnership A Surface Water Management Plan (Surface Water Management Plan) is a framework through which key local partners work together to understand the A partnership group set up to support business growth across Bristol, Bath & causes of surface water, groundwater and/or Ordinary Watercourse flooding North East Somerset, North Somerset, Somerset County Council and South and agree the most cost effective way of managing that risk. Gloucestershire. Includes: business organisations, local authorities, education and training organisations, Government departments and agencies. UK Climate Projections 2009 Wet-spots UK Climate Projections 2009 (UKCP09) is a climate analysis tool, funded by the Department of Environment, Food and Rural Affairs, which features Areas which are considered vulnerable to flooding from surface water, the most current comprehensive climate projections. Projections are broken groundwater, and/ or Ordinary Watercourses (taken from the area-wide down to a regional level across the UK and are shown in probabilistic form, Surface Water Management Plan) illustrating the potential range of changes and the level of confidence in each predictions.

Updated Flood Map for Surface Water National surface water mapping produced by the Environment Agency to facilitate analysis of areas naturally vulnerable to surface water flooding.

UNESCO World Heritage Site Is a place (such as a building, city, complex, desert, forest, island, lake, monument, or mountain) that is listed by the United Nations Educational, Scientific and Cultural Organization (UNESCO) as being of special cultural or physical significance. The list is maintained by the international World Heritage Programme administered by the UNESCO World Heritage Committee, composed of 21 UNESCO member states which are elected by the General Assembly. The City of Bath is a UNESCO World Heritage Site and there is an international obligation to protect its outstanding heritage. Bath & North East Somerset Local Flood Risk Management Strategy APPENDIX F 133